M/S EMERSON AUTOMATION SOLUTIONS INTELLIGENT PLATFORMS PVT. LTD,,BANGALORE vs. DCIT, C-3(1)(2), BANGALORE

ITA 9/BANG/2019Status: DisposedITAT Bangalore30 August 2024AY 2014-15Bench: IN THE INCOME TAX APPELLATE TRIBUNAL BENGALURU “B” BENCH, BENGALURU BEFORE SHRI PRAKASH CHAND YADAV (Judicial Member), SHRI WASEEM AHMED (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal allowed the appeal regarding payments made to headquarters for services received, stating that the genuineness of expenses is key, not necessarily the immediate benefit. Other grounds were allowed for statistical purposes or remanded.

What were the facts?

The assessee, engaged in manufacturing and trading of automation products, filed its return for AY 2014-15. The Transfer Pricing Officer (TPO) made significant adjustments to the assessee's income related to international transactions.

What were the issues?

The primary issues involved the correctness of transfer pricing adjustments, including the applicability of methods, adjustments for custom duty, working capital, and payments to headquarters for services.

Which sections of the Income-tax Act were involved?

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

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Income Tax Appellate Tribunal, BENGALURU “B” BENCH, BENGALURU

Hearing: 13.08.2024Pronounced: 30.08.2024

PER: PRAKASH CHAND YADAV,J.M.

Present appeal of the assessee is arising from the order of ld. AO / DRP dated 30th October, 2018. The assessee has raised 19 grounds of appeal out of which ground Nos. 1 to 5 are general in nature and hence not required specific adjudication. Ground No. 6 related to the grievance of the assessee with respect to the adjustment of custom duty, base cost, working capital not granted by the AO while completing the assessment.

Ground No. 7 is with respect to the applicability of TNMM method

The order continues below.

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