Aztec Software & Technologies Services Ltd. v. Asstt. CIT

107 ITD 141Income Tax Appellate Tribunal2007#1260 most cited

What is Aztec Software & Technologies Services Ltd. v. Asstt. CIT authority for?

OECD Transfer Pricing Guidelines can be referred to for resolving transfer pricing disputes in India, even though India is not an OECD member, provided they are consistent with Indian statutory regulations. Availability of exemption under Section 10A does not bar the applicability of Section 92C and 92CA.

90

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2013 to 2026.

Also referred to as

Aztec Software & Technologies Services Ltd. v. Asstt. CIT · ITAT · 2007 · 107 ITD 141 · OECD Guidelines · Transfer Pricing Policy · Section 10A · Section 92C · Section 92CA · purposive interpretation · benchmarking analysis

Also reported as

162 Taxmann 119

Sections most often in play

Section 143(3)Section 144C(13)Section 144C(5)Section 234CSection 32(1)(ii)Section 37(1)Section 92C(2)Section 10A

Issues it is cited on

section 10b(8)section 132(1)(a)section 92f(ii)section 92(1)purposive interpretationsection 92c(2)cost plus methodsection 43afunctional analysissection 92fbenchmarking analysisr&d expenditure

Judgments citing Aztec Software & Technologies Services Ltd. v. Asstt. CIT

Addl.CIT., -Range-10(2), Mumbai vs. Wns Global Services Pvt.Ltd., Mumbai

In the result, cross objection filed by the assesee is partly allowed

ITA 1451/MUM/2012[2007-08]Status: DisposedITAT Mumbai19 Feb 2020AY 2007-08

Bench: Shri C.N.Prasad & Shri G. Manjunathaaddl.Cit, Range-10(2) Wns Global Services Room No.432, 4Th Floor Pvt.Ltd. Aaykar Bhawan Plant-10, Gate No.4 M.K.Road Vs. Godrej & Boyce Complex Mumbai-400 020 Pirojshanagar, Vikhroli(W) Mumbai-400 079

Section 10ASection 10A(1)Section 9

…IN THE INCOME TAX APPELLATE TRIBUNAL “K”, BENCH MUMBAI BEFORE SHRI C.N.PRASAD, JUDICIAL MEMBER & SHRI G. MANJUNATHA, ACCOUNTANT MEMBER Addl.CIT, Range-10(2) WNS Global Services Room No.432, 4th Floor Pvt.Ltd. Aaykar Bhawan Plant-10, Gate No.4 M.K.Road Vs. Godrej & Boyce Complex Mumbai-400 020 Pirojshanagar, Vikhroli(W) Mumbai-400 079 PAN/GIR No.AAACW2598L Appellant) .. Respondent) & CO.No.44/Mum/2013 (Assessment Year: 2007-08) WNS Global Services Addl.CIT, Range-10(2) Room No.432, 4th Floor Pvt.Ltd. Plant-10, Gate No.4 Aaykar Bhawan Godrej & Boyce Complex Vs. M.K.Road Pirojshanagar, Vikhroli(W) Mumbai-400 02…

Bombay Rayon Holdings Limited, Mumbai vs. ITO-9(2)(2), Mumbai

In the result, appeals of the assessee are partly allowed

ITA 5986/MUM/2018[2009-10]Status: DisposedITAT Mumbai06 Jan 2020AY 2009-10

Bench: Shri Shamim Yahya & Shri Pawan Singh

For Appellant: Shri. Madhur Agrawal, Shri Ajit KumarFor Respondent: Shri. Anand Mohan
Section 131Section 133Section 143(3)Section 144CSection 144C(13)Section 148Section 92(1)Section 92C(1)

…ed upon by the assessee. The transfer pricing officer also rejected the assessee‟s plea that there is no intention of shifting of profits. In this regard, he referred to the decision of ITAT Bangalore special bench in the case of Aztec software and technology 107 ITD 141. Honourable Punjab and Haryana High Court decision in the case of Coca-Cola India Inc 309 ITR 194 another case laws. The Transfer Pricing officer also held that the submission that the assessee is into loss also cannot be reason not charge interest on loans granted to it. In this regard also the Transfer Pricing officer referred to several case l…

DCIT RG 8(2), Mumbai vs. India Medtronic P. Ltd, Baroda

In the result, assessee’s appeal is partly allowed

ITA 4074/MUM/2012[2007-08]Status: DisposedITAT Mumbai16 Oct 2019AY 2007-08

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

For Appellant: Shri Rajan R. Vora a/wFor Respondent: Shri Jayant Kumar

…ransfer Pricing Officer, he could have himself carried out a fresh benchmarking under RPM. In support of such contention, he relied upon the Special Bench decision of Tribunal, Bangalore Bench, in Aztec Software and Technologies Services Ltd. v/s ACIT, [2007] 107 ITD 141 (Gang.)(SB). Thus, he submitted, the issue has to be restored back to the Assessing Officer / Transfer Pricing Officer for undertaking a fresh benchmarking by applying RPM. Without prejudice, he submitted, the comparables selected by the assessee under TNMM are not good comparables. Therefore, if TNMM is accepted as the most appropriate method, t…

Symphony Ltd., Ahmedabad vs. The Dy. Commissioner of Income Tax, Circle-4(1)(1), Ahmedabad

In the result, appeal filed by the assessee

ITA 1057/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad20 Sept 2019AY 2012-13
For Appellant: Shri Bharat Shah, ARFor Respondent: Smt. Vinod Tanwani, CIT- DR
Section 115JSection 143(3)Section 145ASection 14ASection 68Section 92C

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ ‘D’ अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORESHRI MANISH BORAD, ACCOUNTANT MEMBER AND SHRI AMARJIT SINGH, JUDICIAL MEMBER आयकर अपील सं./ITA No.1057/Ahd/2017 { "नधा"रण वष"/Assessment Year:2012-13 Symphony Ltd. Symphony Dy. Commissioner of House, FP 12, TP 50 S. G. Vs Income Tax, Circle-4(1)(1) Highway, Bodakdev, ‘B’ Wing, 2nd Floor, Ahmedabad-380054, Bodakdev, Pratyaksh Kar Bhavan, Ahmedabad-380054. Ahmedabad-15. PAN NO-AACCS6739B अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Appellant by : Shri Bharat Shah, AR Revenue by : Smt. Vinod Tanwani, CIT-…

Mx Systems International P. Ltd, Mumbai vs. DCIT 12(3)(2), Mumbai

In the result the assessee’s appeal in ITA no

ITA 1889/MUM/2015[2010-11]Status: DisposedITAT Mumbai22 Jul 2019AY 2010-11

Bench: Shri Mahavir Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.1889/Mum/2015 (नििाारण वर्ा / Assessment Year: 2010-11) बिाम/ M/S. Mx Systems Dcit 12(3)(2) R.No. 147B, International Private Ltd., Aayakar Bhavan, 202A-202D, Arvind V. Mumbai-400020 Chambers, Western Express Highway, Andheri (E), Mumbai-400069 स्थायी ऱेखा सं./ Pan :Aaecm5026B

For Appellant: Shri. Chetan A. KariaFor Respondent: Shri. Pavan K Beerla (DR)
Section 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 92CSection 92C(3)

…eing the case, the arguments are for argument's sake and devoid of hard and/ or ascertainable facts having bearing on the case under consideration. This issue has been considered and decided by Special Bench of ITAT in the case of M/s. Aztec Software Vs. ACIT 107 ITD 141 (Bang.)(SB), which has held that data for the relevant period alone is to be considered. The use of data only for F.Y.2009-10 is in accordance with the provisions of 92C(3). Accordingly, the objections of the assessee are not found to be tenable. 8.7. The assessee has argued for adjustment to its own PLI for the losses incurred. Adjustments to th…

Minimax Gmbh & Co. Kg, Mumbai vs. DCIT (It) 3(2)(2), Mumbai

In the result the assessee’s appeal in ITA no

ITA 1888/MUM/2015[2010-11]Status: DisposedITAT Mumbai22 Jul 2019AY 2010-11

Bench: Shri Mahavir Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.1889/Mum/2015 (नििाारण वर्ा / Assessment Year: 2010-11) बिाम/ M/S. Mx Systems Dcit 12(3)(2) R.No. 147B, International Private Ltd., Aayakar Bhavan, 202A-202D, Arvind V. Mumbai-400020 Chambers, Western Express Highway, Andheri (E), Mumbai-400069 स्थायी ऱेखा सं./ Pan :Aaecm5026B

For Appellant: Shri. Chetan A. KariaFor Respondent: Shri. Pavan K Beerla (DR)
Section 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 92CSection 92C(3)

…eing the case, the arguments are for argument's sake and devoid of hard and/ or ascertainable facts having bearing on the case under consideration. This issue has been considered and decided by Special Bench of ITAT in the case of M/s. Aztec Software Vs. ACIT 107 ITD 141 (Bang.)(SB), which has held that data for the relevant period alone is to be considered. The use of data only for F.Y.2009-10 is in accordance with the provisions of 92C(3). Accordingly, the objections of the assessee are not found to be tenable. 8.7. The assessee has argued for adjustment to its own PLI for the losses incurred. Adjustments to th…

Gdf Suez Energy India Private Limited, Bangalore vs. ACIT, Bangalore

ITA 984/BANG/2010[2002-03]Status: DisposedITAT Bangalore15 Mar 2019AY 2002-03

Bench: Shri N.V. Vasudevan & Shri G. Manjunathaassessment Year : 2002-03

For Appellant: Shri A. Shankar, AdvocateFor Respondent: Shri Biswaranjan Sasmal, CIT
Section 234B

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI N.V. VASUDEVAN, JUDICIAL MEMBER AND SHRI G. MANJUNATHA, ACCOUNTANT MEMBER Assessment year : 2002-03 Engie Energy and Services India Pvt. Ltd., Vs. The Assistant Commissioner (formerly GDF Suez Energy India Pvt. Ltd.), of Income Tax, Srinivas and Badri Counsels, Circle 3(1)(2), 25/3, 2nd Floor, Lavelle Road, Bangalore. Opp. Nitesh Buckingham Gate, Ashok Nagar, Bangalore – 560 001. PAN: AAACT 5405D APPELLANT RESPONDENT Appellant by : Shri A. Shankar, Advocate Respondent by : Shri Biswaranjan Sasmal, CIT Date of hearing : 12.03.2019 Date of P…

Gulbrandsen Chemicals Pvt.Ltd., Baroda vs. The Dy.CIT., Circle-1(1), Baroda

Appeal of the assessee is allowed, the appeal of the revenue is dismissed

ITA 874/AHD/2012[2007-08]Status: DisposedITAT Ahmedabad12 Feb 2019AY 2007-08
Section 143(3)Section 92

…arms length nature of this transaction and leaving un-bench marked this transaction, ITA No.: 874 and 760/Ahd/2012 Assessment years: 2007-08 Page 21 of 21 contrary to the decision of the Special Bench in the case of Aztee Software & Technology Services Ltd. 107 ITD 141 (BANG), (SB) 38. The relief granted by the CIT(A), which is impugned in the above ground of appeal, is on account of adjustments in computation of internal CUP prices but as, vide our order on the appeal of the assessee, we have upheld the plea of the assessee against CUP being adopted as the most appropriate method for determination of arm’s le…

The DCIT, Circle-1(1), Baroda vs. Gulbrandsen Chemicals Pvt.Ltd., Baroda

Appeal of the assessee is allowed, the appeal of the revenue is dismissed

ITA 760/AHD/2012[2007-08]Status: DisposedITAT Ahmedabad12 Feb 2019AY 2007-08
Section 143(3)Section 92

…arms length nature of this transaction and leaving un-bench marked this transaction, ITA No.: 874 and 760/Ahd/2012 Assessment years: 2007-08 Page 21 of 21 contrary to the decision of the Special Bench in the case of Aztee Software & Technology Services Ltd. 107 ITD 141 (BANG), (SB) 38. The relief granted by the CIT(A), which is impugned in the above ground of appeal, is on account of adjustments in computation of internal CUP prices but as, vide our order on the appeal of the assessee, we have upheld the plea of the assessee against CUP being adopted as the most appropriate method for determination of arm’s le…

DCIT, New Delhi vs. M/S Jsl Ltd., Hisar

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

ITA 4110/DEL/2013[2007-08]Status: DisposedITAT Delhi19 Nov 2018AY 2007-08

Bench: Smt Diva Singh & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Kumar Parnav, Sr. DR
Section 92CSection 92C(2)

…researched by analyzing transactions in similar products to determine typical volume discounts.‖ Attention in this regard is invited to the relevant portion of the order of Special Bench of Tribunal in the case of Aztec Software and Technology Ltd. v. ACIT: 107 ITD 141, where the Tribunal while discussing the applicability of various methods of determining arm‘s length price, provided under the Act, duly considered that the public data available at exchanges, quotation media etc., on the basis of which actual transaction take place in the market, even amongst unrelated parties can be used/ relied upon, while ap…

Jindal Stainless Ltd., Hisar vs. DCIT, New Delhi

Accordingly, ground number 2 of the appeal of the learned AO for 2007 – 08 is dismissed

ITA 6337/DEL/2012[2008-09]Status: DisposedITAT Delhi19 Nov 2018AY 2008-09

Bench: Smt Diva Singh & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Kumar Parnav, Sr. DR
Section 92CSection 92C(2)

…researched by analyzing transactions in similar products to determine typical volume discounts.‖ Attention in this regard is invited to the relevant portion of the order of Special Bench of Tribunal in the case of Aztec Software and Technology Ltd. v. ACIT: 107 ITD 141, where the Tribunal while discussing the applicability of various methods of determining arm‘s length price, provided under the Act, duly considered that the public data available at exchanges, quotation media etc., on the basis of which actual transaction take place in the market, even amongst unrelated parties can be used/ relied upon, while ap…

Sophos Technologies Private Limited, (Formerly Known As Cyberoam Technologies Private Limited), Ahmedabad vs. The Dy. CIT, Circle-4(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1565/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad16 Nov 2018AY 2012-13
Section 143(3)Section 92C

…it is by now acknowledged that granting of excess credit period is a service rendered to the AE and needs to be benchmarked". A reference is then made to Special Bench decision in the case of Aztec Software & Technology Services (P.) Ltd. v. Asstt. CIT [2007] 107 ITD 141/162 Taxman 119 (SB) (Bang.), in support of the proposition that merely by finding fault in the work done by the TPO, the adjustments cannot be deleted and that unless the ALP submitted by the taxpayer is specifically accepted, the appellate authorities, on the basis of material available on record have to determine ALP themselves. 7. We find that…

Bucher Hydraulics Private Limited, Gurgaon vs. Deputy Commissioner of Income-Tax, New Delhi

In the result, the appeal filed by the assessee is allowed

ITA 1650/DEL/2015[2010-11]Status: DisposedITAT Delhi29 Oct 2018AY 2010-11

Bench: Sh. N. K. Billaiya & Smt Suchitra Kambleassessment Year: 2010-11 Bucher Hydraulics Private Deputy Commissioner Of Limited Vs Income Tax Plot No.6, Sector-5 Circle-5 (1) Imt Manesar Gurgaon New Delhi Pan Aaecs5991H (Appellant) (Respondent)

Section 116Section 143Section 92

…e Income Tax Act, 1961 by the Assessing Officer was illegal being contrary to (i) the binding Instruction No.3/2003, (ii) the provisions of Section 92 CA and the binding decision of the Special Bench in the case of Aztec Software and Technology Services Ltd. [107 ITD 141 (Bang) (SB) / 2007- TIOL-210-ITAT-BANG-SB]. Consequently, the impugned assessment is time barred and, therefore, bad in law.” 2. Before us the Ld. Counsel stated that in A. Y. 2007-08 and 2008-09 similar additional grounds were raised before the Tribunal and the Tribunal in ITA No. 4237/Del/2011 and 5690/Del/2012 for A. Y. 2007-08 and 2008-09 ad…

Gemstone Glass Pvt. Ltd., Kadi vs. The Dy. CIT, Circle-3(1)(1), Ahmedabad

In the result, appeal is allowed in the terms indicated above

ITA 414/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad23 Oct 2018AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy1. It(Tp)A No.3533/Ahd/2015 - Ay 2010-11 2. It(Tp)A No.3631/Ahd/2015 - Ay 2011-12 3. It (Tp)A No.414/Ahd/2017 - Ay 2012-13

For Appellant: Shri Suhail DuttFor Respondent: Ms. Vasundhara Upmanyu, CIT-DR
Section 143(3)Section 144CSection 154

…"it is by now acknowledged that granting of excess credit period is a service rendered to the AE and needs to be benchmarked". A reference is then made to Special Bench decision in the case of Aztec Software &Technology Services (P.) Ltd. v. Asstt. CIT [2007] 107 ITD 141/162 Taxman 119 (SB) (Bang.), in support of the proposition that merely by finding fault in the work done by the TPO, the adjustments cannot be deleted and that unless the ALP submitted by the taxpayer is specifically accepted, the appellate authorities, on the basis of material available on record have to determine ALP themselves. 7. We find tha…

Gemstone Glass Pvt. Ltd., (Successor in Pino Bisaza Glass Pvt. Ltd.), Kadi vs. The Dy.CIT, Circle-3(1)(1), Ahmedabad

In the result, appeal is allowed in the terms indicated above

ITA 3631/AHD/2015[2011-12]Status: DisposedITAT Ahmedabad23 Oct 2018AY 2011-12

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy1. It(Tp)A No.3533/Ahd/2015 - Ay 2010-11 2. It(Tp)A No.3631/Ahd/2015 - Ay 2011-12 3. It (Tp)A No.414/Ahd/2017 - Ay 2012-13

For Appellant: Shri Suhail DuttFor Respondent: Ms. Vasundhara Upmanyu, CIT-DR
Section 143(3)Section 144CSection 154

…"it is by now acknowledged that granting of excess credit period is a service rendered to the AE and needs to be benchmarked". A reference is then made to Special Bench decision in the case of Aztec Software &Technology Services (P.) Ltd. v. Asstt. CIT [2007] 107 ITD 141/162 Taxman 119 (SB) (Bang.), in support of the proposition that merely by finding fault in the work done by the TPO, the adjustments cannot be deleted and that unless the ALP submitted by the taxpayer is specifically accepted, the appellate authorities, on the basis of material available on record have to determine ALP themselves. 7. We find tha…

Gemstone Glass Pvt. Ltd., (Successor in Pino Bisaza Glass Pvt. Ltd.), Kadi vs. The Dy.CIT, Circle-3(1)(1), Ahmedabad

In the result, appeal is allowed in the terms indicated above

ITA 3533/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad23 Oct 2018AY 2010-11

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy1. It(Tp)A No.3533/Ahd/2015 - Ay 2010-11 2. It(Tp)A No.3631/Ahd/2015 - Ay 2011-12 3. It (Tp)A No.414/Ahd/2017 - Ay 2012-13

For Appellant: Shri Suhail DuttFor Respondent: Ms. Vasundhara Upmanyu, CIT-DR
Section 143(3)Section 144CSection 154

…"it is by now acknowledged that granting of excess credit period is a service rendered to the AE and needs to be benchmarked". A reference is then made to Special Bench decision in the case of Aztec Software &Technology Services (P.) Ltd. v. Asstt. CIT [2007] 107 ITD 141/162 Taxman 119 (SB) (Bang.), in support of the proposition that merely by finding fault in the work done by the TPO, the adjustments cannot be deleted and that unless the ALP submitted by the taxpayer is specifically accepted, the appellate authorities, on the basis of material available on record have to determine ALP themselves. 7. We find tha…

At&S India Private Limited, Karnataka vs. D.C.I.T., Circle-11(1), Kolkata

In the result, appeal filed by the assessee, is allowed

ITA 69/KOL/2018[2013-14]Status: DisposedITAT Kolkata10 Oct 2018AY 2013-14

Bench: Shri S. S. Godara, Jm & Dr. A.L.Saini, Am At&S India Private Limited Vs. Dcit, Circle 11(1), Kolkata P-7, Chowringhee Square, 12A, Industrial Area, Nanjangud – 571 301 Kolkata – 700 069. Mysore District, Karnataka, India "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaeca 2930 J (अपीलाथ" /Appellant) (""यथ" / Respondent) ..

For Appellant: Shri Anup Sinha & Ms. Rituparna Sinha, ARFor Respondent: Shri P.K. Srihari, CIT, DR
Section 143(3)Section 144C(13)Section 37(1)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL “C”, BENCH KOLKATA BEFORE SHRI S. S. GODARA, JM & DR. A.L.SAINI, AM AT&S India Private Limited Vs. DCIT, Circle 11(1), Kolkata P-7, Chowringhee Square, 12A, Industrial Area, Nanjangud – 571 301 Kolkata – 700 069. Mysore District, Karnataka, India "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AAECA 2930 J (अपीलाथ" /Appellant) (""यथ" / Respondent) .. Appellant by : Shri Anup Sinha & Ms. Rituparna Sinha, AR Revenue by : Shri P.K. Srihari, CIT, DR सुनवाई क" तार"ख / Date of Hearing : 16/08/2018 घोषणा क" तार"ख/Date of Pronouncement: 10/10/2018 आदेश / O R D E R Per Dr. Arjun Lal Saini, A…

DCIT, Circle - 11(1), Kolkata vs. M/S. J. J. Exporters Ltd., Kolkata

ITA 1372/KOL/2017[2009-10]Status: DisposedITAT Kolkata19 Sept 2018AY 2009-10

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

Section 92C

…This contention, if taken to a logical conclusion, would amount to obliterating the proviso itself, which is patently incorrect. 9.4. Our view is fortified by the Special Bench order in the case of Aztech Software and Technology Services Ltd. vs. ACIT (2007) 107 ITD 141 (SB) (Bangalore) in which similar issue has been decided by the Special Bench by holding that availability of exemption u/s 10A to the assessee is no bar to applicability of sections 92C and 92CA. Similar view has been taken by Pune Bench of the Tribunal in the case of ACIT vs. MSS India (P) Ltd. (2009) 123 TTJ 657 (Pune) and several other orders…

DCIT, Circle - 11(1), Kolkata vs. M/S. J. J. Exporters Ltd., Kolkata

ITA 1371/KOL/2017[2008-09]Status: DisposedITAT Kolkata19 Sept 2018AY 2008-09

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

Section 92C

…This contention, if taken to a logical conclusion, would amount to obliterating the proviso itself, which is patently incorrect. 9.4. Our view is fortified by the Special Bench order in the case of Aztech Software and Technology Services Ltd. vs. ACIT (2007) 107 ITD 141 (SB) (Bangalore) in which similar issue has been decided by the Special Bench by holding that availability of exemption u/s 10A to the assessee is no bar to applicability of sections 92C and 92CA. Similar view has been taken by Pune Bench of the Tribunal in the case of ACIT vs. MSS India (P) Ltd. (2009) 123 TTJ 657 (Pune) and several other orders…

Evalueserve.Com Pvt. Ltd., Gurgaon vs. ACIT, New Delhi

ITA 1466/DEL/2015[2010-11]Status: DisposedITAT Delhi03 Aug 2018AY 2010-11

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 143(3)Section 144CSection 92C

…DELHI BENCH: ‘I-1’ NEW DELHI BEFORE SHRI R. K. PANDA, ACCOUNTANT MEMBER AND MS SUCHITRA KAMBLE, JUDICIAL MEMBER I.T.A .No. 6310/DEL/2012 (A.Y 2008-09) Evalueserve.Com Pvt. Ltd. Vs ACIT 701, Guru Apartments, Circle-8(2) Sector-14, Rohini New Delhi New Delhi AAACE8014F (APPELLANT) (RESPONDENT) AND I.T.A .No. 1466/DEL/2015 (A.Y 2010-11) Evalueserve.Com Pvt. Ltd. Vs ACIT 2nd Floor, Tower-A, Circle-8(2) Unitech World-Cyber Park, Jharsa, New Delhi Sector-39 Gurgaon AAACE8014F (RESPONDENT) (APPELLANT) Appellant by Ms. Ananya Kapoor, Adv Sh. Salil Kapoor, Adv Respondent by Sh. Kumar Pranav, Sr. DR Date of Heari…