CVENT INDIA PVT. LTD.,,GURGAON vs. ACIT, NEW DELHI

ITA 187/DEL/2016Status: DisposedITAT Delhi26 March 2025AY 2011-12Bench: SHRI MAHAVIR SINGH, VICE PRESIDENT, SHRI NAVEEN CHANDRA (Accountant Member)30 pages
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What did the Tribunal hold?

The Tribunal held that certain comparable companies were incorrectly excluded by the TPO and others were incorrectly included. The matter was set aside for re-determination of ALP adjustments based on the correct set of comparables.

What were the facts?

The assessee, an Indian subsidiary of a US company, provided BPO services to its Associated Enterprises (AEs). The Transfer Pricing Officer (TPO) made an adjustment to the arm's length price (ALP) of these international transactions, which the assessee disputed.

What were the issues?

The key issues were the selection of comparable companies for transfer pricing analysis and the determination of arm's length price for international transactions between associated enterprises.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 92D

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Income Tax Appellate Tribunal, DELHI ‘I’ BENCH,

Before: SHRI MAHAVIR SINGH, & SHRI NAVEEN CHANDRA

For Appellant: Shri Himanshu Sinha, Adv, Shri Prashant Meharchandani &, Shri Jainender Kataria, Adv
Hearing: 08.01.2025Pronounced: 26.03.2025

PER NAVEEN CHANDRA, ACCOUNTANT MEMBER:

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The above captioned two separate appeals by the assessee and cross appeal by the Revenue are preferred against orderdated 30.01.2017 of the ld. CIT(A) –38, New Delhi for A.Y 2010-11 and appeal of the assessee against order of ACIT, Cir 6(2), New Delhi dated

The order continues below.

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