M/S. EATON TECHNOLOGIES PRIVATE LTD.,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,

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ITA 519/PUN/2015Status: DisposedITAT Pune16 August 2021AY 2010-1122 pages
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What did the Tribunal hold?

The Tribunal found that certain comparables required further verification and directed the Assessing Officer/TPO to re-examine them. Specifically, for Future Capital Holdings Limited, the issue of Related Party Transactions was remanded for verification. For Future Capital Investment Advisors Limited, the TPO was directed to follow the DRP's specific directions on margin determination.

What were the facts?

The assessee appealed against the upward adjustment made by the Transfer Pricing Officer (TPO) and Dispute Resolution Panel (DRP) regarding international transactions related to IT, ITeS, and BSS segments. The primary dispute revolved around the selection and benchmarking of comparable companies.

What were the issues?

The key issues were the selection of functionally comparable companies and the correct determination of arm's length price (ALP) for international transactions, including margin calculations and the application of filters.

Which sections of the Income-tax Act were involved?

Section 92C

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Income Tax Appellate Tribunal, “C” BENCH, PUNE

Before: SHRI R.S.SYAL, VP & SHRI PARTHA SARATHI CHAUDHURY, JM

For Appellant: Shri Vishal Kalra & Shri S.S Tomar
For Respondent: Shri Amol Kamat
Hearing: 11.08.2021/12.08.2021Pronounced: 16.08.2021

आदेशानुसार / BY ORDER, // True Copy // धनजी सधचव / Private Secretary आयकर अपीलीय अधधकरण, पुणे / ITAT, Pune.

Date 1 Draft dictated on 11.08.2021 Sr.PS/PS 2 Draft placed before author 16.08.2021 Sr.PS/PS 3 Draft proposed and placed JM/AM before the second Member 4 Draft discussed/approved by AM/JM second Member 5 Approved draft comes to the Sr.PS/PS Sr. PS/PS 6 Kept for pronouncement on Sr.PS/PS 7 Date of uploading of order Sr.PS/PS 8 File sent to Bench Clerk Sr.PS/PS 9 Date on which the file goes to the Head Clerk 10 Date on which file goes to the A.R 11 Date of dispatch of order

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