ARIBA TECHNOLOGIES INDIA PVT LTD,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BENGALURU

ITA 1587/BANG/2024Status: DisposedITAT Bangalore07 March 2025Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the AO was bound to give effect to the revised directions of the DRP and the TPO's revised order. Therefore, the AO was directed to delete the entire transfer pricing adjustment made in respect of software development and IT-enabled services.

What were the facts?

The assessee's appeal concerned transfer pricing adjustments made by the AO. Initially, the DRP granted partial relief, but a subsequent rectification order by the DRP and TPO eliminated the adjustment entirely. However, the AO failed to incorporate this revised direction in the final assessment order.

What were the issues?

Whether the AO correctly incorporated the revised directions of the DRP and TPO's revised order in the final assessment order, and whether the transfer pricing adjustment should be deleted.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 143(3),Section 144C

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Income Tax Appellate Tribunal, ‘A’ BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

For Appellant: Mr. Aliasgar Rampurawala, C.A
For Respondent: Ms. Nandini Das, CIT (DR)
Hearing: 17.12.2024Pronounced: 07.03.2025

PER WASEEM AHMED, ACCOUNTANT MEMBER:

This is an appeal filed by the assessee against the assessment order dated 26/06/2024 in ITA No. ITBA/AST/S/143(3)/2024-25/ 1066102806(1) for the assessment year 2020-21. 2. The issue raised by the assessee through ground No. 1 of its appeal is general in nature and does not require any separate adjudication. Hence the same is dismissed as infructuous.

IT(TP)A No.1587/Bang/2024 3. The issue raised by the assessee through ground Nos. 1 (a) and (b) pertains to the validity of the

The order continues below.

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