M/s Trianz Holdings Pvt Ltd , Bangalore vs Deputy Commissioner of Income TAx Circle-7(1)(1), Bangalore

IN THE INCOME TAX APPELLATE TRIBUNAL
BANGALORE BENCHES “C”, BANGALORE

Before Shri George George K, JM & Shri B.R.Baskaran, AM
IT(TP)A No.2522/Bang/2017 : Asst.Year 2013-2014

M/s.Trianz Holdings Pvt. Ltd.
#165/2, 6th Floor, Kalyani
Magnum, Doraisanipalaya, IIM
Post, Bannerghatta Road
Bangalore – 560 076.
PAN : AAFAC8051P.
(Appellant) 

v.

The Dy.Commissioner of
Income-tax, Circle 7(1)(1)
Bangalore.
(Respondent)

Appellant by : Sri.K.R.Vasudevan, Advocate
Respondent by : Sri.Pradeep Kumar, CIT-DR
Date of Hearing : 15.12.2020
Date of 
Pronouncement : 15.12.2020

O R D E R

Per George George K, JM

This appeal at the instance of the assessee is directed against final assessment order dated 27.09.2017 passed u/s 143(3) r.w.s. 144C(13) of the I.T.Act. The relevant assessment year is 2013-2014.

2. The brief facts of the case are as follow: The assessee is a company engaged in the business of providing information technology services. For the assessment year 2013-2014, the return of income was filed on 19.11.2013 declaring loss of Rs.5,55,17,930. The assessment was taken up for scrutiny by issuing of notice u/s 143(2) of the I.T.Act. During the course of assessment proceedings, the matter was referred to the Transfer Pricing Officer (TPO) for determining the Arm’s Length Price (ALP) of International Transaction undertaken by the assessee with its holding company in U.S.A. After considering the assessee’s objection, the total adjustment made u/s 92CA of the I.T.Act was Rs.28,27,00,781. The Assessing Officer included the arm’s length adjustment in the draft assessment order passed u/s 143(3) r.w.s. 144C(1) of the I.T.Act. The assessee aggrieved, filed the objections before the Dispute Resolution Panel (DRP). The DRP vide its order dated 21.08.2017 did not give any relief on this issue to the assessee.Consequently, directions of the DRP with regard to adjustmentmade to the ALP was incorporated in the final assessment order dated 27.09.2017.

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