DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 6(1)(2), BENGALURU vs. M/S. STATE STREET SERVICES (INDIA) PRIVATE LIMITED, BENGALURU
What did the Tribunal hold?
The Tribunal has corrected minor errors in its previous order. These corrections clarify the nature of services discussed and the appellate authority involved in the proceedings.
What were the facts?
This is a corrigendum to a previous ITAT order. The corrections involve substituting specific terms in the original order, such as changing 'SWD services' to 'IT enabled services' and 'Disputes Resolution Panel (DRP)' to 'CIT(Appeals)'.
What were the issues?
The key issues involved were the nature of services provided and the correct appellate authority to be referenced in the order.
AI-generated summary — verify with the full judgment below
Per N.V. Vasudevan, Vice President
The appeal and the cross objection has been disposed of by this Tribunal vide order dated 31.08.2020. However, it is noticed that certain errors are to be modified in the order of the Tribunal, which are substituted to read as follows:-
Corrigendum to IT(TP)A No.2193/Bang/2019 & CO 1/Bang/2020 Page 2 of 2 (1) In para 6, page 4 of the aforesaid order of the Tribunal, the sentence reads as “Thus a sum of Rs.1,81,22,863/- was added to the total income of the Assessee on account of determination of ALP for provision of SWD services by the assessee to its AE”. The words “SWD services” is substituted to read as “IT enabled services”.
(2) In para 7 of the order, the opening sentence reads as “The Assessee filed objections before the Disputes Resolution Panel (DRP) against the draft assessment order ….”, wherein the words “CIT(Appeals)” is substituted in placed of ‘Disputes Resolution Panel (DRP)’.
(3) At page 5, para 9 of the order, in the sentence “As far as appeal of revenue is concerned, by ground No.2 the revenue seeks exclusion of Acropetal Technologies Ltd. as a comparable company, the word “inclusion” is substituted for ‘exclusion’.
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