APPLEXUS TECHNOLOGIES PRIVATE LIMITED,TRIVANDRUM vs. DCIT, KOTTAYAM

ITA 955/COCH/2024Status: DisposedITAT Cochin13 November 2025AY 2021-20221 pages
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What did the Tribunal hold?

The tribunal held that the authorities below erred in rejecting the segmental accounts and transfer pricing documentation without appreciating the material on record. The rejection of segmental details was contrary to the evidence, and the TPO/DRP failed to consider the impact of COVID-19.

What were the facts?

The assessee, a private limited company providing SAP consulting services, challenged the transfer pricing adjustment made by the TPO and DRP. The authorities rejected the assessee's transfer pricing documentation and computed the profit-level indicator (PLI) at the entity level.

What were the issues?

Whether the transfer pricing documentation and segmental analysis provided by the assessee were correctly rejected by the TPO/DRP, and whether the PLI should be computed at the entity level or on a segmental basis.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C,Section 144B,Section 144C(5),Section 92CA(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “DB” BENCH, COCHIN

[ Per Rahul Chaudhary, Judicial Member:

1.

The present appeal has been preferred by the Assessee challenging Final Assessment Order, dated 13/09/2024, passed by the Assessing Officer under Section 143(3) read with Section 144C read with Section 144B of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’], as per the directions issued by Dispute Resolution Panel - 2, Bengaluru [for short ‘DRP’], on 12/08/2024 under Section 144C(5) of the Act for the Assessment Year 2021-2022. 2. The Assessee has raised multiple grounds of appeal which can be grouped as under: Ground No.1: Incorrect

The order continues below.

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