2022 (1) TMI 1301

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.... Shri S. Palani Kumar- Ld. CIT- DR O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aggrieved by confirmation of certain Transfer-pricing adjustment for Assessment Year (AY) 2009-10, the assessee is in further appeal before us. The final assessment order has been passed by Ld. Assessing Officer (AO) on 28.02.2014 u/s 143(3) r.w.s. 144C(13) & 92CA(3) of the Act pursuant to the directions....

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....t by the assessee with its Associated Enterprises (AE) during the year were referred to Ld. TPO for determination of Arm's Length Price (ALP). One of the transactions was rendering of services by the assessee in the area of IT enabled services (ITeS). This transaction was benchmarked using Transactional Net Margin Method (TNMM). In its Transfer Pricing study report, the assessee computed average m....

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.... by Ld. TPO in its order dated 31.12.2012. However, this adjustment has been revised by Ld. TPO to Rs.656.08 Lacs in rectification order dated 08.03.2013 passed u/s 154. The same was incorporated in the draft assessment order dated 22.03.2013 which was subjected to objections before Ld. DRP. 4. The Ld. DRP, after considering assessee's submissions, directed for exclusion of one entity, however, r....