2025 (8) TMI 1380

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....the case as coming out from the orders of authorities below are that the assessee is a wholly owned subsidiary of Striker Far East Inc. Hong Kong. It operates in the healthcare industry and is primarily engaged in importing medical/surgical products, manufactured by its group companies. The assessee is also engaged in marketing and distribution of these items in India. For the year under consideration, there were two segments in which the assessee was doing its business, one is trading segment and one is marketing support service segment. The dispute in the present appeal is only with respect to the marking support services segment. The assessee has applied TNMM method for the computation of Arm's Length Price (ALP) for this segment. The me....

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....e facts and circumstances of the case and in law, the Ld. Assistant Commissioner of Income Tax, Circle 22(2), New Delhi ("Ld. AO") following the directions of the Hon'ble Dispute Resolution Panel ("DRP"), erred in enhancing the income of the Appellant by INR 2,35,91,515/-, on account of Transfer Pricing ("TP") adjustment u/s 92CA(3) of the Income-tax Act, 1961 ("the Act") 2. On the facts and circumstances of the case and in law, the Ld. AO/Ld. Transfer Pricing Officer (Ld. TPO), erred in enhancing the income of the Appellant by INR 1,67,29,006 with regard to international transactions pertaining to provision of Marketing Support Services by 2.1 not accepting the economic analysis undertaken by the Appellant in accordan....

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...., disregarding that outstanding payable to AEs should also be taken into consideration while computing the interest income of receivables. 5. On the facts and circumstances of the case and in law, the Ld. AO/Ld. Transfer Pricing Officer (Ld. TPO), erred in initiating penalty proceedings u/s 270A of the Act. That the above grounds of appeal are without prejudice to each other. That the Appellant reserves its right to add, alter, amend or withdraw any ground of appeal either before or at the time of hearing of this appeal." 5. So far as ground No.1 is concern, it is general in nature and, hence, does not require any specific adjudication. 6. In Ground No.2 to 2.3, the assessee is challenging the action of TPO ....