M/S. COMPUTER SCIENCE CORPORATION INDIA PVT. LTD.,CHENNAI vs. THE ACIT-CIRCLE 2(1), INDORE

ITA 292/IND/2017Status: DisposedITAT Indore10 April 2023AY 2012-13Bench: MS. SUCHITRA KAMBLE (Judicial Member), SHRI BHAGIRATH MAL BIYANI (Accountant Member)29 pages
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What did the Tribunal hold?

The Tribunal found that the issue of exempt income and its nexus with expenditure under Section 14A was not properly demonstrated by the assessee. Consequently, the matter was remanded to the Assessing Officer for verification.

What were the facts?

The assessee, M/s. Computer Sciences Corporation, filed appeals against assessment orders for AYs 2011-12, 2012-13, and 2013-14. The appeals primarily concerned disallowances under Section 14A and transfer pricing adjustments.

What were the issues?

The key issues were the validity of disallowances under Section 14A and the correctness of transfer pricing adjustments made by the revenue authorities.

Which sections of the Income-tax Act were involved?

Section 14A,Section 143(3),Section 144C,Section 92C,Section 92F

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Cases cited in this judgment(23)Show list

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Heard together (2 matters)

ITA Nos.179/Ind/2016
SA No.46/Ind/2021

Read from the judgment's own cause title. This page is filed under one of them.

ITA Nos.179/Ind/2016, 292/Ind/2017, 319/Ind/2018 & SA No.46/Ind/2021 A.Ys. 2011-12, 2012-13 & 2013-14 IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE

BEFORE MS. SUCHITRA KAMBLE, JUDICIAL MEMBER AND SHRI BHAGIRATH MAL BIYANI, ACCOUNTANT MEMBER

(Conducted through Virtual Court) Assessment Year: 2011-2012

M/s. Computer Sciences Corporation vs. The Asstt. Commissioner of India Private Limited, Income Tax – 2(1), 19A, Electronic Complex, Indore. Aatmaram Choudhary Marg, Near Readymade Complex, Pardeshipura, Indore – 452 010. [PAN – AABCC 5820 A] Assessment Year: 2012-13

M/s. Computer Sciences Corporation vs. The Asstt. Commissioner of India Private Limited, Income Tax, Circle – 2(1), 7th Floor, Block-1B, DLF IT Park, Indore. Shivaji Garden, Moonlight Stop, Nandanbakkam Post-Ramapuram, Chennai, Tamilnadu – 600 089. [PAN – AABCC 5820 A] Assessment Year: 2013-14

M/s. Computer Sciences Corporation vs. The Dy. Commissioner of India Private Limited, Income Tax, Circle – 2(1), 7th Floor, Block-1B, DLF IT Park, Indore. Shivaji Garden, Moonlight Stop, Nandanbakkam Post-Ramapuram, Chennai, Tamilnadu – 600 089. [PAN – AABCC 5820 A]

S.A. No.46/Ind/2021 (Arising out of I

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