Court :
ITAT Bangalore
Brief :
The present cross appeals have been filed by assessee as well as revenue against order dated 21/12/2015 passed by the Ld.ACIT Circle 1(1)(1) Bangalore under section 143 (3) read with section 144C(5) read with section 144C(13) of the Act, for assessment year 2011-12 on following grounds of appeal:
Citation :
IT(TP)A No.208/Bang/2016
IN THE INCOME TAX APPELLATE TRIBUNAL
‘C’ BENCH : BANGALORE
BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER
AND
SMT. BEENA PILLAI, JUDICIAL MEMBER
IT(TP)A No.208/Bang/2016
Assessment Year : 2011-12
M/s Altisource Business
Solutions Pvt.Ltd.,
Pritech Park,Survey number
51 to 64/4,Block Number12,3rd Floor A wing,Bellandur
village,Sarjapur Marathahalli
Outer Ring Road,
Bangalore-560103.
PAN – AAACO9467A
APPELLANT
Vs.
Asst. Commissioner of
Income-Tax,
Circle -1(1)(1),
Bangalore.
RESPONDENT
IT(TP)A No.209/Bang/2016
Assessment Year : 2011-12
Asst. Commissioner of
Income-Tax,
Circle -1(1)(1),
Bangalore.
APPELLANT
Vs.
M/s Altisource Business
Solutions Pvt.Ltd.,
Pritech Park,Survey
number 51 to 64/4,Block
Number-12,3rd Floor A
wing,Bellandur
village,Sarjapur
Marathahalli Outer Ring
Road,
Bangalore-560103.
PAN – AAACO9467A
RESPONDENT
Assessee by : Shri K.R Vasudevan, Advocate
Revenue by : Shri Shishir Srivastava, CIT
Date of Hearing : 07-04-2021
Date of Pronouncement : 02-07-2021
ORDER
PER BEENA PILLAI, JUDICIAL MEMBER
The present cross appeals have been filed by assessee as well as revenue against order dated 21/12/2015 passed by the Ld.ACIT Circle 1(1)(1) Bangalore under section 143 (3) read with section 144C(5) read with section 144C(13) of the Act, for assessment year 2011-12 on following grounds of appeal:
ITA No.208/B/2016
The learned Assessing Officer ("learned AO"), learned Transfer Pricing Officer
("learned TPO") and the Honourable Dispute Resolution Panel ("Hon'ble DRP") grossly erred in adjusting the transfer price by INR 15,17,38,598/- of the Appellant's international transactions with its Associated Enterprises ("AEs") with respect to the Software Development Services ("IT") and IT Enabled Services ("ITeS") rendered by the tax payer u/s 92CA of the Income- tax Act, 1961.
2. The learned AO/learned TPO/Hon'ble DRP erred in rejecting the TP documentation maintained by the Appellant by invoking provisions of subsection (3) of 92C of the Act.
3. The learned AO/learned TPO/Hon'ble DRP erred in rejecting comparability analysis carried in the TP documentation and in conducting a fresh comparability analysis by introducing various filters in determining the ALP.
4. The learned AO/learned TPO/Hon'ble DRP erred in not considering the previous two years financial data of the comparable companies while determining the ALP.
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