MSD PHARMACEUTICALS PVT. LTD.,NEW DELHI vs. DCIT CIRCLE-16(1), NEW DELHI

The present appeal has been filed by the assessee against the order dated 29.06.2021 passed by the AO u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961.

At the outset, the assessee submitted that the adjustment in ALP stands rectified and hence the TP issues are not being pressed.

The BLT approach being a non-recognized method as held by the various courts cannot be invoked.

The issue of deduction of Education Cess is ruled against the assessee in view of the judgment of Hon’ble Supreme Court

In the result, the appeal of the assessee is dismissed. Order Pronounced in the Open Court on 07/02/2023.