KNORR-BREMSE TECHNOLOGY CENTRE INDIA PRIVATE LIMITED,PUNE vs. DY. CIT, CIRCLE-14, PUNE

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ITA 1957/PUN/2019Status: DisposedITAT Pune16 February 2022AY 2015-1616 pages
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What did the Tribunal hold?

The Tribunal set aside the impugned order and remitted the matter to the AO/TPO for re-deciding the transfer pricing adjustment after revising the comparable companies' data set. The issue of interest levy under Section 234A was also remanded for re-adjudication.

What were the facts?

The assessee challenged transfer pricing adjustments made by the TPO and DRP, primarily concerning the selection of comparable companies. The assessee also raised issues regarding the AO's use of an incorrect transfer pricing adjustment amount and the levy of interest.

What were the issues?

The main issues were the selection of comparable companies for transfer pricing, the correct amount of transfer pricing adjustment, and the levy of interest under various sections of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 144C,Section 143(3),Section 92CA,Section 154,Section 234A,Section 271(1)(c),Section 274,Section 234B,Section 234C

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Income Tax Appellate Tribunal, ‘B’ BENCH, PUNE

Before: SHRI R.S.SYAL, VP & SHRI PARTHA SARATHI CHAUDHURY, JM

For Appellant: Shri M.P. Lohia &, Shri Nikhil Tiwari
For Respondent: Shri Shivaji B. More

per law while complying with the principles of natural justice. Ground No.10 of the assessee’s appeal is allowed for statistical purposes.

22.

In the combined result, the appeal of the assessee is partly allowed for statistical purposes.

Order pronounced in the open Court on this 16th February 2022.

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