2025 (5) TMI 330

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ee at the time of hearing and, after going through the proceedings recorded so far in the order sheet, it appears the assessee is not inclined to contest the appeal. As for completeness, the proceedings recorded on 14.08.2024 are reproduced below:- "Assessee represented by: Shri Neeraj Jain Soni, AR Department represented by: Shri Rajesh Kumar, CIT (DR) An adjournment application dated 14/08/2024 was received in the matter. As per case records, the matter is very old and languishing for nearly 7 years in defiance of the spirit of section 254(2A) of the Act. Multiple opportunities were given to Assessee in the past. Having regard to totality of circumstances, a last opportunity is provided to Assessee, to present its case on the next dat....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....loyees Contribution 1,689,740 3. Loans/Advances written off 743,473 4. Travelling and conveyance expenses 4,697,320 Sub-total of additions/disallowances B 187,039,945 Income assessed as per draft assessment order C=A+B 159,967,177         5. In the TP order dated 29 January 2016, the learned TPO did not agree with the analysis undertaken by the Assessee for the international transactions pertaining to provision of IT enabled services and provision of IT and related services to AEs ("also referred to as impugned transactions") and rejected the TP documentation maintained by the Assessee. As with regard to the Provision of IT enabled services and IT and related services, the learned TPO did not concur....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....a of 12 month period i.e. 01 April 2011 to 31 March 2012; c. Reject companies having a turnover of less than INR 1 crore; d. Rejection of companies whose software development services/ IT enabled services is less than 75 percent of its total operating revenues; e. Rejection of companies whose export income is less than 75 percent of the sales; f. Rejection of companies having more than 25 percent related party transactions (RPT)  (sales as well as expenditure combined) of the sales. g. Rejection of companies that have employee cost that is less than 25 percent of turnover; h. Reject companies that are affected by peculiar economic circumstances (including persistent losses, declining sales, etc); and i. Reject companies t....