2024 (10) TMI 1641

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....t, C.A For the Revenue : Ms. Neera Malhotra, CIT (DR) ORDER PER WASEEM AHMED, ACCOUNTANT MEMBER: This is an appeal filed by the assessee against the order passed by the ld. CIT-1,2,3, Bengaluru dated 06/06/2024 in DIN No. ITBA/AST/S/ 143(3)/2024-25/1065451410(1) for the assessment year 2020-21. 2. The only issue raised by the assessee is that the AO/DRP erred in making upward adjust....

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....ment order made the addition of Rs. 31,89,289/- to the total income of the assessee. 5. Being aggrieved by the order of the AO/DRP, the assessee is in appeal before us. 6. The ld. AR before us submitted that the assessee as per the agreement with the AE was to grant credit for 90 days, which has not been considered by the AO/DRP in his order. Accordingly, the ld. AR submitted that there cann....

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....elied on the order of this Tribunal in the case of DCIT Vs. Hewlett Packard India Software Operations Private Limited (2022) 149 taxmann.com 280 (Bang. Trib.). 9. We have heard the rival contentions of both the parties and perused the materials available on record. In the light of the above discussion, we are of the view that the issue on hand needs to be revisited at the level of the TPO so as....