2020 (8) TMI 828

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..... We have carefully heard the rival submissions and perused relevant material on record. The material on record would show that the assessee being resident corporate assessee stated to be engaged in manufacturing of various types of process gas compressors etc. was assessed u/s 143(3) r.w.s. 144C vide order dated 21/01/2011. In the said order, the assessee was saddled with certain Transfer Pricing (TP) Adjustments of Rs. 726.84 Lacs on account of international transactions in the nature of cost contribution allocation as carried out by the assessee with its associated enterprises. These adjustments were proposed by Ld. Transfer Pricing Officer in its order u/s 92CA(3) dated 15/10/2010. While framing the assessment, these adjustments were in....

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.... assessee's ground nos. 1 to 6 would not survive and accordingly, stand dismissed as being infructuous. We order so. 5.1 The only surviving ground in assessee's appeal is ground no.7 which read as under: - Ground No.7 - Additions under Section 145A of the Act of Rs. 81,61,042/- 7. On the facts and circumstances of the case and in law, learned CIT(A) has erred in confirming addition of Rs. 81,61,042/- made under section 145A of the Act. The appellant prays that the adjustment under Section 145A on account of unutilized CENVAT credit to the closing stock is unwarranted and be deleted. 5.2 The relevant facts are that during the course of assessment proceedings, it was noted by Ld. AO that the assessee followed exclusive method of accoun....