CPA Global Support Services India Pvt. Ltd., New Delhi ACIT, New Delhi

Last updated: 10 February 2021

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This Income Tax Appellate Tribunal case involves M/s. CPA Global Support Services India Pvt. Ltd. appealing an addition of INR 13,30,04,676 to their returned income for the 2012-13 assessment year. The addition was made by the Assessing Officer, Dispute Resolution Panel, and Transfer Pricing Officer based on a re-computation of the arm's length price of international transactions under Section 92 of the Income-Tax Act.

Court :
ITAT New Delhi

Brief :
Appellant, M/s. CPA Global Support Services India Pvt. Ltd.(hereinafter referred to as ‘the taxpayer’) by filing the presentappeal sought to set aside the impugned order dated 13.01.2017passed by the Assessing Officer (AO) in consonance with the orders passed by the ld. DRP/TPO under section 143 (3) read with section 144C of the Income-tax Act, 1961 (for short ‘the Act’) qua the assessment year 2012-13 on the grounds inter alia that :-

Citation :
ITA No.1524/Del./2017

IN THE INCOME TAX APPELLATE TRIBUNAL
(DELHI BENCH ‘I-1’ : NEW DELHI)

BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER
and
SHRI KULDIP SINGH, JUDICIAL MEMBER
(THROUGH VIDEO CONFERENCE)

ITA No.1524/Del./2017
(ASSESSMENT YEAR : 2012-13)

M/s. CPA Global Support Services India
(PAN : AABCI1509C)
(APPELLANT)

vs.

ACIT, Circle 6 (2),
Private Limited, New Delhi.
1/3, 2nd Floor, Sir Gangaram Hospital Marg,
Old Rajinder Nagar,
New Delhi – 110 060.
(RESPONDENT)

ASSESSEE BY : Shri Manomeet Dalal, Advocate
Shri Vishu Goel, AR
REVENUE BY : Shri Surender Pal, CIT DR
Date of Hearing : 22.12.2020
Date of Order : 03.02.2021

O R D E R

PER KULDIP SINGH, JUDICIAL MEMBER :

Appellant, M/s. CPA Global Support Services India Pvt. Ltd.(hereinafter referred to as ‘the taxpayer’) by filing the presentappeal sought to set aside the impugned order dated 13.01.2017passed by the Assessing Officer (AO) in consonance with the orders passed by the ld. DRP/TPO under section 143 (3) read with section 144C of the Income-tax Act, 1961 (for short ‘the Act’) qua the assessment year 2012-13 on the grounds inter alia that :-

“1. That on the facts and in the circumstances of the case and in law, the Hon'ble Dispute Resolution Panel ("DRP")/ Learned Assessing Officer ("AO")/ Learned Transfer Pricing Officer ("TPO") erred in making addition to the returned income of the appellant by INR 13,30,04,676/- by re-computing the arm's length price ("ALP") of international transactions under section 92 of the Income-Tax Act, 1961 ("the Act").

To know more in details find the attachment file