2015 (10) TMI 1453

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ason for disregarding the Arm's Length Price and without granting due opportunity of being heard to the assessee while making the reference alongwith other grounds as raised in the grounds of appeal. 2. During hearing, the ld. counsel for the assessee, Shri Ajit Tolani, advanced his arguments which are identical to the ground raised challenging upholding the entire adjustment made to the total income of the assessee which was based upon the order of the TPO and further upheld by the ld. Commissioner of Income tax (Appeals). The ld. Counsel took us to the various pages of the voluminous paper book filed by the assessee claiming that the necessary details were filed by the assessee right from assessment stage itself which were not consider....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... the assessee. The assessee filed revised return at Rs. 8,51,81,900/- on 3rd March, 2009. The assessee vide letter dated 4th August, 2010, also filed revised computation of income, adding back entire expenses relating to technical service fees, having regard to the provisions of section 40(a)(i) of the Act revising its total income to Rs. 26,03,03,593/- and paid taxes along with interest on the revised income. During the year under consideration, the assessee entered into international transactions with its Associated Enterprises (AE) within the meaning of section 92 of the Act. The TPO carried out transfer pricing assessment and passed order u/s 92CA(3) of the Act making addition of Rs. 20,18,57,196/- on account of payment for management a....