ITAT : Relies McKinsey's earlier years' MAP settlement to determine taxability in subsequent year

Mumbai ITAT holds that taxability of Rs. 150 cr. received by assessee-company (part of the Mckinsey Group based in US) in India during AYs 2011-12 and AY 2012-13 shall be determined as per the MAP settlement for earlier years; Notes that as per the terms of MAP settlement for AYs 2008-09 to 2009-10, it was agreed that payment for providing various consultancy services (including Knowledge Pool Charges, Borrowed Service Charges, Firm Committee Pool Charge, Regional Corporate Finance Charges etc.) to its AE  shall not be taxable in India as ' Royalty ' or ' Fees for Included Service (‘FIS’) '; ITAT rejects Revenue’s stand that the MAP settlement being year-specific, cannot be made applicable to subject assessment years; Notes that the MAP settlement is with respect to amount paid by Mckinsey India to other Mckinsey entities in USA; Relies on co-ordinate bench rulings  in assessee’s own case and in case of its group companies which accepted for applying the MAP terms of earlier years:ITAT