DIMAGI SOFTWARE INNOVATIONS PRIVATE LIMITED,NEW DELHI vs. THE INCOME TAX OFFICER, WARD 28(1), NEW DELHI

ITA 5894/DEL/2024Status: DisposedITAT Delhi07 August 2026AY 2021-2215 pages
AI SummaryPartly Allowed

What were the facts?

The assessee challenged the assessment order which included corporate tax additions and transfer pricing adjustments. The Dispute Resolution Panel (DRP) had issued directions regarding the use of segmental information for comparables and working capital adjustments, which the assessee argued were not followed by the Assessing Officer (AO) and Transfer Pricing Officer (TPO).

What did the Tribunal hold?

The Tribunal held that the AO/TPO did not deliberately defy DRP directions. However, due to non-availability of segmental data for some comparables and lack of supporting evidence for corporate issues, the matter was restored to the AO/TPO for recomputation. The assessee was directed to furnish necessary details for working capital adjustments and corporate issues.

What were the issues?

Whether the AO/TPO followed the binding directions of the DRP, and whether the disallowances for GST, TDS, and foreign exchange loss were justified due to lack of supporting evidence.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B,Section 10B(2),Section 10B(3),Section 43AA,Section 234A,Section 234B,Section 270A,Section 153

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH, I: NEW DELHI

Before: Ms. KAVITHA RAJAGOPAL & SMT. RENU JAUHRI

For Appellant: Ms. Pallavi Dinodia, CA, Shri R.K. Kapoor, CA, Ms. Monika Bhardwaj, CA &, Ms. Deepti Gupta, CA
For Respondent: Shri Mahesh Kumar, CIT(DR)
Hearing: 25.06.2026Pronounced: 07.08.2026

Per Renu Jauhri, Accountant Member:

This appeal by the assessee is against the final assessment order dated 29.10.2024 passed by the DC/ACIT (TP) 1(2)(1),Delhi, (hereinafter referred to as the ‘ld. AO’) under Section 143(3) r.w.s. 144C(13) read with Section 144B of the Income-tax Act, 1961 (“the Act”), pursuant to the directions of the Hon'ble Dispute

ITA no.- 5894/Del/2024 Dimagi So"ware Innova"ons Pvt. Ltd. Resolution Panel-1, New Delhi (DRP) order dated 28.03.2024 for the Assessment Year 2021-22. 2. Grounds of appeal filed by the assessee are reproduced as under:

“1. That the Assessment or

The order continues below.

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