2024 (6) TMI 466

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....spondent : Shri Rajesh Kumar, CIT-DR ORDER PER VIKAS AWASTHY, JM: This appeal by the assessee is directed against the assessment order dated 26.10.2018 passed u/s 143(3) r.w.s 144C(6) of the Income Tax Act 1961 (hereinafter referred to as 'the Act'), for assessment year 2014-15. 2. This appeal was filed by the assessee in December 2018. Initially the assessee was represented by Shri Ve....

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....unsel for the assessee. Thereafter, in remaining part of year 2020 the appeal could not be heard as the Bench did not function on account of Covid-19 pandemic. The hearing of appeal resumed on 23.02.2021, on the said date again the appeal was adjourned at the request of assessee's counsel. Thereafter, the appeal was repeatedly adjourned at the written request of counsel for the assessee on followi....

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.... of ld. DR and on the basis of documents already on record. 3. Shri Rajesh Kumar, representing the Department vehemently defended the impugned assessment order and the order of TPO. 4. The assessee in appeal has primarily raised two grounds assailing the assessment order and the directions of the DRP i.e. (i) Adjustment on account of foreign exchange fluctuation gains; and (ii) Transfer Pric....

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....ment to engineering segment and made following adjustments: SI.No Segment Amount of adjustment in INR 1 Trading Segment 504,518,505 2 Engineering service segment 95,989,974   Total 600,508,479 5. Aggrieved by the transfer pricing adjustments, the assessee filed objections before the Dispute Resolution Panel (DRP). The DRP vide directions dated 18.09.2018....