2020 (12) TMI 1367

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....DR ORDER Per George George K, JM This appeal at the instance of the assessee is directed against final assessment order dated 27.09.2017 passed u/s 143(3) r.w.s. 144C(13) of the I.T.Act. The relevant assessment year is 2013-2014. 2. The brief facts of the case are as follow: The assessee is a company engaged in the business of providing information technology services. For the assessment y....

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....8.2017 did not give any relief on this issue to the assessee. Consequently, directions of the DRP with regard to adjustment made to the ALP was incorporated in the final assessment order dated 27.09.2017. 3. Aggrieved by the final assessment order, the assessee has filed this appeal before the Tribunal. Though several grounds are raised, the learned AR by referring to ground No.3, submitted that ....

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.....2020), after examining the facts of the case, had accepted the contention of the assessee that the TPO conducted transfer pricing analysis on erroneous understanding of the business model of the assessee. Accordingly, the entire transfer pricing issue was set aside to the TPO with a direction that the transfer pricing analysis may be carried out having regard to the business model of the assessee....

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....o directed that comparables selected should be functionally similar with assessee, having similar business model like assessee. 20. Assessee is directed to produce all relevant documents to bring out its role in providing services to the parties situated outside India. Ld.TPO is also directed to grand working capital adjustments in comparables in actual where ever necessary, for computing corre....