2021 (6) TMI 1126

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.... assessment year 2014-15. 2. The only issue raised in this appeal is against the transfer pricing addition of Rs.9,18,00,388/-. Briefly stated, the facts of the case are that the assessee is a wholly owned subsidiary of Automated Securities Clearance LLC, USA and is a part of SunGard group. The assessee is engaged in providing Information Technology Enabled Services (ITES) through its Shared Service Centre located in Pune. The assessee filed its return declaring total income of Rs.1,37,010/-. Certain international transactions were reported in Form No. 3CEB. The AO made a reference to the Transfer Pricing Officer (TPO) for determining the Arm's Length Price (ALP) of the international transactions. The only international transaction under ....

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....ctional profile of the assessee under the transaction. There is no dispute as to the nature of business carried on by the assessee as the TPO has accepted in his show cause notice as reproduced at page 3 of his order that "the assessee is engaged in the business of IT enabled service (ITeS)". On a pertinent query, the ld. AR submitted that no formal agreement was entered into between the assessee and its Associated Enterprise (AE) for rendering the ITES. Such services were rendered pursuant to a Purchase order, a copy of which has been placed at page 1 of the paper book. This Purchase order is effective from 01-04-2012 and is valid till 31-03-2014, thereby covering the year under consideration. As per the terms and conditions, it has been p....