Vedanta Limited, New Delhi ACIT, Circle-26(2), New Delhi

IN THE INCOME TAX APPELLATE TRIBUNAL
(DELHI BENCH ‘I-2’ : NEW DELHI)
(THROUGH VIDEO CONFERENCE)
BEFORE
SHRI ANIL CHATURVEDI, ACCOUNTANT MEMBER
and
SHRI KULDIP SINGH, JUDICIAL MEMBER
ITA No. 9495/Del./2019
A. Y. : 2015-16

M/s. VEDANTA LIMITED 
PAN : AACCS7101B
(APPELLANT) 

Vs. 

ACIT
(Successor to M/s. Cairn India Ltd.) Circle-26(2)
Core-6, 3rd Floor, Lodhi Road,
New Delhi-110003 New Delhi
(RESPONDENT)

S.A. 248/ Del/ 2020
Arising out of ITA No. 9495/Del./2019
A. Y. : 2015-16
M/s. VEDANTA LIMITED 
PAN : AACCS7101B
(APPELLANT) 

Vs. 

ACIT
(Successor to M/s. Cairn India Ltd.) Circle-26(2)
Core-6, 3rd Floor, Lodhi Road,
New Delhi-110003 New Delhi
(RESPONDENT)

ASSESSEE BY : Shri Ajay Vohra, Sr. Adv.
REVENUE BY : Shri Ajit Kr. Singh, CIT-DR
Date of Hearing : 07.12.2020
Date of Order : 24.12.2020

O R D E R

PER KULDIP SINGH, JUDICIAL MEMBER

Appellant, M/s. Vedanta Limited (hereinafter referred to as ‘the taxpayer’) by filing the present appeal sought to set aside theimpugned order dated 28/11/2019 passed 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 2015-16 on the grounds inter alia that :-

2. Briefly stated the facts necessary for adjudication of the controversy at hand are : M/s. Vedanta Limited, the taxpayer is into the business of exploring & drilling, developing, producing refining, marketing of minerals and oil bye-products and other activities incidental to the above. Apart from its business activities, the taxpayer also holds interests in its subsidiary companies which have been granted right to explore and develop oil exploration blocks in the Indian sub-continent. The main source of revenue is sale of crude oil and natural gas from the blocks at Rajasthan and Canbay Offshore and Ravva Block (KG Basin). During the year under assessment, the taxpayer entered into international transactions and specified domestic transactions as mentioned in Form 3CEB with its Associated Enterprises (AEs) as under :-

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