ORDER :

The petitioner is aggrieved by the impugned order dated 13.10.2018 passed by the 1st respondent Deputy Commissioner of Income Tax, Transfer Pricing Officer for the assessment year 2015-16.

2. By the impugned order, it has been concluded that Arm’s Length Price (ALP) towards Corporate Service Fee was considered as “Nil” thereby resulting in a downward adjustment of Rs.5,83,25,839/- towards corporate support service fees.

3. By the impugned order, the 1st respondent has concluded that the petitioner had failed to substantiate receipt of service and demonstrate the economic and commercial benefits on account of the payments made to its associated enterprice.

4. The main contention of the petitioner in this writ petition is that despite a precedent on the very same issue for the assessment year 2013-14 vide order dated 14.5.2018 in ITA.No.2977/CHNY/2017, the 1st respondent has passed the impugned order dated 30.8.2018 under Section 92 CA(3) of the Income Tax Act, 1961.

5. The learned counsel for the petitioner submits that an identical issue came up for consideration before the Tribunal in the above case in ITA.No.2977/CHNY/2017. It is submitted that the Tribunal vide order dated 14