VERINT SYSTEMS (INDIA) PVT. LTD. vs. INCOME-TAX OFFICER,

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ITA/275/2016HC DelhiDLHC01110080201603 May 2017Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE CHANDER SHEKHAR1 pages

AI SummaryWithdrawn

What did the High Court hold?

The High Court noted that the issue regarding the adjustment of working capital, which had not been considered by the ITAT, was subsequently addressed by the ITAT in its order dated March 31, 2017. Consequently, the Assessee stated that it had no further grievance concerning the transfer pricing study for the Assessment Year in question. The Assessee's counsel requested that the grounds urged in the appeal be left open for future consideration. In light of these developments, the High Court disposed of the appeal.

What were the facts?

The appeal was filed by Verint Systems (India) Pvt. Ltd. (the Assessee) against an order of the Income Tax Officer (the Revenue). The Assessment Year is not explicitly stated. The Assessee had a grievance regarding a transfer pricing study. However, the Assessee subsequently filed an application before the Income Tax Appellate Tribunal (ITAT) concerning an issue of working capital adjustment that had not been considered. The ITAT considered this issue in an order dated March 31, 2017. As a result, the Assessee stated that it had no further grievance concerning the transfer pricing study for the Assessment Year under consideration.

What were the issues?

The primary issue before the High Court was the Assessee's grievance concerning the transfer pricing study. However, the judgment indicates that a specific aspect of this, the adjustment of working capital, was subsequently addressed by the ITAT. The Assessee's counsel stated that the grounds urged in the appeal should be left open for consideration in another appropriate case. No specific arguments from the Revenue are recorded in this order.

AI-generated summary — verify with the full judgment below

$~12 * IN THE HIGH COURT OF DELHI AT NEW DELHI +

ITA 275/2016

VERINT SYSTEMS (INDIA) PVT. LTD. ..... Appellant

Through: Mr. Harpreet Singh, Advocate

versus

INCOME-TAX OFFICER

..... Respondent Through: Mr. Ashok K. Manchanda & Mr. Raghvendra Singh, Advocates

CORAM: JUSTICE S.MURALIDHAR JUSTICE CHANDER SHEKHAR

O R D E R %

03.05.2017 1. It is stated that one of the issues regarding adjustment of working capital which had not been considered by the Income Tax Appellate Tribunal (‘ITAT’) has subsequently been considered by it on an application filed by the Appellant/Assessee before the ITAT, by an order dated 31st March, 2017. It is stated that in that view of the matter, there is no grievance as such of the Assessee as regards the transfer pricing study for the Assessment Year under consideration. Learned counsel for the Assessee states that the grounds urged by the Assessee in its appeal be left open for consideration in any another appropriate case.

The appeal is, accordingly, disposed of.

S.MURALIDHAR, J

CHANDER SHEKHAR, J MAY 03, 2017/tp

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