2020 (3) TMI 1281

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.... For the Respondents : Y.V.S.T. Sai, CIT-DR ORDER P. Madhavi Devi, Member (J) Both are assessee's appeals for the A.Ys. 2012-13 & 2011-12 respectively. The assessee was formerly known as Apollo Health Street Ltd. 2. Brief facts of the case are that the assessee-company, which is engaged in the business of IT Enabled Services and BPO service provider, filed its returns of income fo....

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....e A.Y. 2012-13: "On the facts and in the circumstances of the case and in law, the Learned AO/DRP has: GENERAL GROUND 1. Erred in assessing the total income of the Appellant at Rs. 22,81,83,328 as against Rs. 14,41,93,240 under normal provisions of the Act as computed by the Appellant in its return of income. TRANSFER PRICING MATTERS- 2. Making adjustme....

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....antee by determining the benefit to US wholly owned subsidiary in terms of interest savings on account of the guarantee extended. e) Without prejudice, not following the Hon'ble Tribunal rulings and judicial precedents on applicability of TP to similar guarantee and determination of ALP. CORPORATE TAX ISSUES 3. Levying of interest u/s. 234B and 234C on the Transfer P....

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..../Hyd/2014 & 132/Hyd/2014, (A.Y. 2009-10) dt. 30-06-2014 and also the copies of the order in ITA Nos. 435/Hyd/2015 & 332/Hyd/2015 (A.Y. 2010-11) dt. 21-10-2016 in which the issue was remitted to the file of the AO/TPO for fresh consideration. 4. Ld. DR was also heard. 5. Having regard to the rival contentions and material on record, we find that the TP adjustment on corporate guarantee were r....