TaxTMI 
TaxTMI 
2025 (6) TMI 1388
X X X X Extracts X X X X
X X X X Extracts X X X X
....d before the Circle - 6(1)(1), Bangalore under PAN AAICS2894R. For the FY 2020-21 relevant to AY 2021-22. The Assessee is engaged in the business of providing Information technology services specific to the payments industry to customers such as banks, financial institutions, third party processors and to its AEs. Assessee, filed its return of income for the AY 2021-22 on 14.03.2022 declaring total income of Rs. 34,84,89,630/-. The case was selected for complete scrutiny under CASS and notice under section 143(2) of the Act was issued to the Assessee. Subsequently, a reference under Section 92CA(1) of the Income Tax Act, 1961 (in short "The Act") was made by the Jurisdictional Assessing Officer ('AO') to the Transfer Pricing Officer....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... adjustments and assessed the income of the Assessee. 2.3 Aggrieved by the above orders of the AO and Ld. TPO, the Assessee filed its objections before the ld. Dispute Resolution Panel ('DRP'). In its directions dated 24.09.2024, the ld. DRP upheld the TPO's approach for computation of arm's length price with respect to the SWD segment. Regarding the imputation of interest on receivables and the adjustment on cross charge payable to AE's by the AO, the ld. DRP upheld the positions taken by the TPO and AO. Based on the directions of the ld. DRP, the ld. TPO affirmed the original TP adjustment of Rs. 29,88,44,824/ Factoring this, the final assessment order dated 23.10.2024 was passed in the Assessee's case. 3. The assess....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... fresh consideration at the end of TPO, therefore, we restore this issue to the file of TPO for examining afresh. The contentions raised by the assessee being ground Nos.5 & 6 remained open vis-à-vis inclusion and exclusion of the comparables by applying the appropriate filter. Needless to say that the TPO will grant meaningful opportunity before passing any order. 8. Next ground nos. i.e. 7 & 8, they are related to the imputation of interest on delayed receivables by the TPO. In these grounds, assessee has basically argued that these outstanding receivables is not per se an international transaction and hence cannot be subjected to TP adjustments. The second argument that in any case LIBOR+200 is the appropriate rate to be applied ....