GALLAGHER SERVICE CENTER LLP (FORMERLY KNOWN AS GALLAGHER OPERATIONS SUPPORT SERVICES P LTD),PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, NFAC,, DELHI

ITA 679/PUN/2022Status: DisposedITAT Pune24 March 2025AY 2018-19Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)20 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The tribunal partially allowed the appeal, directing the exclusion of certain companies found not comparable and remanding the issue of another company's comparability for fresh adjudication. The tribunal also dismissed grounds not adjudicated.

What were the facts?

The assessee, a captive service provider, appealed against an assessment order concerning international transactions with its associated enterprise. The core issue was the determination of the arm's length price for business support services.

What were the issues?

The key issues revolved around the appropriateness of comparable companies selected for transfer pricing analysis and the rejection of the assessee's comparability study, as well as the levy of penalty.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(3),Section 144B,Section 92CA,Section 270A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCHES “C” :: PUNE

Before: DR.DIPAK P. RIPOTE & SHRI VINAY BHAMORE

For Appellant: Shri M.P.Lohia – AR
For Respondent: Shri Prakash L Pathade – CIT(DR)
Hearing: 23/01/2025Pronounced: 24/03/2025

PER DR.DIPAK P.RIPOTE, AM : This is an appeal filed by the assessee against the Assessment Order of passed under section 143(3) r.w.s 144C(3) read with section 144B of the Income Tax Act, 1961; dated 15.07.2022 for A.Y.2018-19. The Assessee has raised the following grounds of appeal : “Based on the facts and circumstances of the case, the Appellant respectfully craves leave to prefer an appeal under section 253(1)(d)

ITA No.679/PUN/2022 [A]

of the Income-tax Act, 1961 (hereinafter referred to as Act) against the order dated 15 July 2022 (received by the Appellant on 15 July 2022) passe

The order continues below.

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