AVEVA SOLUTIONS INDIA LLP,HYDERABAD vs. INCOME TAX OFFICER., WARD- 8(1), HYDERABAD
What did the Tribunal hold?
The Tribunal directed the exclusion of six companies from the list of comparables for transfer pricing adjustment, as per previous coordinate bench decisions. It also directed the deletion of interest charged under Section 234A as the return was filed within the due date.
What were the facts?
The assessee, engaged in software development and IT-enabled services, filed its return of income. The Assessing Officer (AO) made transfer pricing adjustments and other additions based on the Dispute Resolution Panel's (DRP) directions. The assessee appealed the final assessment order.
What were the issues?
Whether certain companies were correctly included as comparables for transfer pricing. Whether interest under Section 234A was leviable when the return was filed within the due date.
Which sections of the Income-tax Act were involved?
Section 143(3),Section 144C(13),Section 144B,Section 92CA(3),Section 139(1),Section 234A
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, Hyderabad ‘A‘ Bench, Hyderabad
Before: Shri Ravish SoodShri Madhusudan Sawdia
Per Madhusudan Sawdia, A.M.:
This appeal is filed by M/s. Aveva Solutions India LLP (“the assessee”), feeling aggrieved by the assessment order passed by the Assessing Officer (“AO”) under section 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (“the Act”) as per the directions of the Learned Dispute Resolution Panel-1 Bengaluru (“Ld. DRP”) dated 23.07.2024 for the A.Y. 2020-21. 2
The assessee has raised the following grounds of appeal:
6
The brief facts of the case are that th
The order continues below.
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