2018 (3) TMI 1814

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....The appeal filed by the Revenue is against the order of DCIT, Circle-1(1), Pune, dated 24.02.2015 relating to assessment year 2010-11 passed under section 143(3) r.w.s. 144C(13) of the Income-tax Act, 1961 (in short 'the Act'). 2. The Revenue has raised the following ground of appeal:- 1. On the facts and in the circumstances of the case, the Ld. Dispute Resolution Panel erred in directing the ....

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....44C of the Act vide order dated 26.12.2014. The final assessment order was passed under section 143(3) r.w.s. 144C(13) of the Act on 24.02.2015, against which though, the DRP had given certain directions, but TP adjustment of Rs. 2.69 crores was made. Thereafter, an order was passed under section 154 of the Act on 23.04.2015, wherein no addition was made in the hands of assessee. The TPO while mak....

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.... Vs. Dana India Technical Centre Pvt. Ltd. in ITA No.592/PN/2013, relating to assessment year 2008-09, order dated 30.03.2016. 7. We have heard the rival contentions and perused the record. The limited issue which arises in the present appeal is against determination of PLI for the year under consideration. The assessee during the year under consideration had debited certain prior period expense....

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....lier year expenses for determining PLI of the year under appeal. 9. We find similar issue arose before the Tribunal in ACIT Vs. Dana India Technical Centre Pvt. Ltd. (supra) and it was held as under:-  "12...... The learned Authorized Representative for the assessee fairly conceded before us that out of total losses of approximately Rs. 62 lakhs, losses to the tune of about Rs. 35 lakhs r....