SCHNEIDER ELECTRIC INDIA PVT. LTD.,GURGAON vs. ACIT, NEW DELHI

ITA 1076/DEL/2016Status: DisposedITAT Delhi09 April 2025AY 2007-08Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI PRADIP KUMAR KEDIA (Accountant Member)33 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found considerable force in the assessee's plea regarding errors by the lower authorities. Consequently, all issues were restored to the TPO/AO for fresh determination.

What were the facts?

The assessee, Schneider Electric India Pvt. Ltd., challenged transfer pricing adjustments made by the TPO/AO concerning the purchase of raw materials, R&D support services, and business support services. The assessee also contested the denial of deduction under Section 10A.

What were the issues?

Whether the transfer pricing adjustments made by the TPO were erroneous, and whether the assessee was eligible for deduction under Section 10A.

Which sections of the Income-tax Act were involved?

Section 10A,Section 92C,Section 92D,Section 143(3),Section 144C,Section 254

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Income Tax Appellate Tribunal, DELHI “I” BENCH: NEW DELHI

Before: SHRI VIKAS AWASTHY & SHRI PRADIP KUMAR KEDIA

For Appellant: Shri Rohit Tiwari, Adv. &
For Respondent: Shri Rajesh Kumar Dhanesta, Sr.DR
Hearing: 17.01.2025Pronounced: 09.04.2025

PER PRADIP KUMAR KEDIA, AM : The captioned appeal has been filed at the instance of the assessee against the assessment order dated 30.12.2015 passed under s. 144C r.w.s. 143(3) r.w.s. 254 of the Income Tax Act, 1961 [“the Act”] in pursuance to the direction of Dispute Resolution Panel (“DRP”) pertaining to assessment year 2007-08. The assessee has raised the following grounds of appeal:- Transfer pricing matter “That on the facts and circumstances of the case, and in law:

1.

The assessment order passed by the Learned Assessing Officer ('Ld. AO') is bad in law;

2.

The AO/Ld. TPO have erred on facts an

The order continues below.

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