TaxTMI 
TaxTMI 
2015 (4) TMI 500
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.... development and modification services related to providing semi-conductors systems solutions for semi conductor based products. It is also engaged in a board development (testing) which is inter-related and inter-connected with software development/designing of chips. Prior to 01.04.2006 it was known as Conexant Systems (PB) P. Ltd., Pune. It was wholly owned subsidiary of Paxonet Systems Inc. USA and there were two other subsidiaries viz., Conexant Systems Noida P. Ltd., Noida and Conexant Systems India P. Ltd., Hyderabad. Pursuant to the scheme of amalgamation all these three companies got merged into one company having its registered office at Hyderabad. Prior to amalgamation, Conexant India (PB) Ltd., filed its return of income for the....
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....hereafter, the case of the assessee was transferred to Hyderabad after the merger of all the three subsidiaries and a fresh reference was made by the A.O. i.e., ACIT, Circle (1), Hyderabad to the TPO for determining the arms length price of the international transactions of the assessee company with its AEs. Accordingly, the TPO vide his order dated 28.12.2012 passed under section 92CA(3) of the Act, determined the arms length price of the relevant international transactions of the assessee company with its AE at Rs. 26,15,50,020 as against the price of Rs. 24,24,52,978 charged by the assessee and worked out the TP adjustment to be made in the case of the assessee at Rs. 1,90,97,040. 2.1. In the draft assessment order dated 28.02.2013 the ....
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.... also perused the material on record. In the grounds raised in this appeal, the assessee has challenged the validity of assessment made by the A.O. as well as the addition made therein on account of T.P. adjustment on merit. In respect of the preliminary issue raised in this appeal by the assessee challenging the validity of the assessment made by the Assessing Officer, the Ld. Counsel for the assessee has invited our attention to the copy of reasons recorded by the A.O. placed at page nos. 161 and 162 of the paper book. He has pointed that the assessment for the year under consideration was reopened by the A.O. on the basis of TPO's order dated 30.10.2009 proposing T.P. adjustment of Rs. 1.88 crores and disallowance of assessee's claim of ....