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
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