DIMENSION DATA INDIA LTD, MUMBAI vs ADDL CIT RG 2(1), MUMBAI

IN THE INCOME TAX APPELLATE TRIBUNAL
“K” BENCH, MUMBAI

BEFORE HON’BLE SHRI VIKAS AWASTHY, JM AND
HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM
(Hearing through video conferencing mode)
IT(TP)A No.1155/Mum/2014
Assessment Year:2009-10)

Dimension Data India Limited
Unit No.204-206, 2nd Floor
Trade Centre Building
Kamala Mills Compound
S.B. Marg, Lower Parel, Mumbai-400 013.
Appellant)

Vs.

Addl. CIT
Range No.551, 5th Floor
Aaykar Bhavan, M.K. Road
Churchgate, Mumbai-400 020.
PAN/GIR No. AAACD-2145-G
Respondent

Appellant by : Shri Vijay Mehta- Ld. AR
Respondent by : Shri Anand Mohan-Ld. DR
Date of Hearing : 24/09/2020
Date of Pronouncement : 17/12/2020

O R D E R

Manoj Kumar Aggarwal (Accountant Member): -

1. Aforesaid appeal by assessee for Assessment Year (AY)2009-10 contest certain additions/disallowances and certain Transfer Pricing (TP) adjustments made by Learned AssessingOfficer (AO) in final assessment order dated 20/12/2013 passedDispute Resolution Panel-1, Mumbai [DRP] u/s 144C (5) dated 31/10/2013. The grounds raised by assessee read as under: -

GROUND NO 1: RELATING TO TRANSFER PRICING ADJUSTMENT OF RS. 58,31,458/- FOR TECHNICAL SUPPORT SERVICE RENDERED TO THE OVERSEAS ASSOCIATED ENTERPRISE: Based on the facts and circumstances of the case and in law, the Additional Commissioner of Income Tax, Circle, Range -2(1), Mumbai (hereinafter referred to as the 'AO') grossly erred, in conformity with the directions of Hon'ble Dispute Resolution Panel ('DRP'), Mumbai under section 144C(13) of the Income Tax Act, 1961 ('the Act') in making transfer pricing adjustment of Rs.58,31,458/- in respect oftechnical support services rendered by appellant to its overseas associated enterprise ('"AE"). The appellant humbly submits that no transfer pricing adjustment is warranted in its case and wishes to raise the following grounds of appeal, which are without prejudice to each other:

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