2026 (6) TMI 364

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.....w.s 144B of the Income Tax Act, 1961 (hereinafter 'the Act') in pursuance of directions of the ld. Dispute Resolution Panel-1, New Delhi (in short 'ld. DRP') dated 08.06.2024 pertaining to Assessment Year 2020-21. 2. Brief facts of the case are that the assessee is a BSE listed company and engaged in the business of manufacturing wide range of Energy Meters including Energy Meters for Smart Grid and tailor made metering solutions for the Indian and global markets. The company is also engaged in the business of generating power by using technologies in the domain of Wind, Bio-fuels and Solar Energy. 3. The return of income for A.Y. 2020-21 was electronically filed on 12.02.2021 declaring income of Rs. Nil/-. After that, the return....

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....er u/s 143(3) r.w.s 144C(13) r.w.s. 144B in pursuance to directions of the Ld. DRP u/s 144C(5) confirming the TP Adjustment of Rs. 64,89,000/- u/s 92CA(3). 2. That the Ld. DRP/ Ld. TPO has erred in law and on facts by questioning the business expediency of Legal and Professional expenses (Intra Group Services, IGS) and determining their Arm's length Price at "NIL", without appreciating that these expenses were legitimate and incurred for business purposes only. 3. That the Ld. DRP has erred in law and on facts by confirming Ld. TPO's approach to reject "Other Method" applied by the appellant and benchmarking Legal and Professional expenses (IGS) under CUP Method: 3.1. without following the methodology pres....