M/s SAP Labs India Private Limited , Bangalore Deputy Commissioner of Income Tax Circle-6(1)(1), Bangalore

This case involves an appeal by M/s SAP Labs India Private Limited against the Deputy Commissioner of Income Tax concerning their assessment for the 2012-13 financial year. The core issue revolves around international transactions with associated enterprises exceeding ₹15 crores, leading to a reference to the Transfer Pricing Officer (TPO). The TPO examined the economic details of these transactions to ensure compliance with transfer pricing regulations.

IN THE INCOME TAX APPELLATE TRIBUNAL
‘A’ BENCH : BANGALORE

BEFORE SHRI. B. R. BASKARAN, ACCOUNTANT MEMBER
AND
SMT. BEENA PILLAI, JUDICIAL MEMBER

 ITA No.684/BANG/2017
Assessment Year : 2012 – 13 

M/s SAP Labs India Pvt.
Ltd.,No.138, Export Promotions
Industrial Park,
Whitefield,
Bengaluru-560 066.
PAN – AAFCS 3649 P
APPELLANT 

Vs.

The Dy. Commissioner of
Income-tax,
Circle-6(1)(1),
Bengaluru.
RESPONDENT 

Appellant by : Shri Aliasgar Ram Purawala, C.A
Respondent by : Ms. Neera Malhotra, CIT

Date of Hearing : 01-07-2021
Date of Pronouncement : 23-07-2021

ORDER

PER BEENA PILLAI, JUDICIAL MEMBER

Present appeal has been filed by assessee against the final assessment order dated 31/01/2017 passed by Ld. DCIT circle 6 (1) (1), Bangalore for assessment year 2012-13 on following grounds of appeal: 

Brief facts of the case are as under:

2. The Assessee filed his return of income on 23/11/2012 declaring total income of Rs.64,48,31,500/-. The return was processed under section 143 (1) of the Act. The case was selected for scrutiny and notices under section 143 (2) was issued to assessee, in response to which, representative of assessee appeared before the Ld.AO and filed requisite details as called for.

2.1 During the year under consideration, the Ld.AO observed that, assessee had international transaction with its associated enterprises that exceeded Rs. 15 crores. Accordingly, reference was made under section 92C of the Act, to the Ld.TPO. The Ld. TPO on receipt of reference called upon assessee to file economic details of the international transaction entered into by assessee with its AE.

2.2 From the details filed by assessee, Ld.TPO observed that assessee had following international transaction with its associated enterprises:

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