2019 (1) TMI 1999

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....RDER The aforesaid appeal has been filed by the assessee challenging the assessment order dated 4th January 2016, passed under section 143(3) r/s 144C(13) of the Income Tax Act, 1961 (for short "the Act") for the assessment year 2011-12, in pursuance to the directions of the Dispute Resolution Panel-2 (DRP), Mumbai. 2. Brief facts are, the assessee, an Indian Company, provides consultancy/advis....

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....39;s length price by an amount of Rs. 9,08,60,000. In pursuance to the order passed by the Transfer Pricing Officer, the Assessing Officer passed the draft assessment order adding the transfer pricing adjustment made by the Transfer Pricing Officer. Against the draft assessment order so passed, the assessee raised objections before the DRP. However, the DRP rejected the objections of the assessee.....

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.... 2015. A paper book containing additional evidences was also submitted before the DRP on 24th September 2015. He submitted, neither the written submission nor the additional evidences furnished by the assessee were taken note of or considered by the DRP while disposing off assessee's objections. He submitted, though, the assessee had filed an application under section 154 of the Act before the DRP....

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.... the assessee and evidences filed to justify its claim that there is no international transaction of revenue nature and also objecting to the transfer pricing adjustment made by the Transfer Pricing Officer were not considered by the DRP. In our considered opinion, if for justifying its claim that no transfer pricing adjustment was required to be made in the given facts and circumstances of the ca....