Emerson Climate Technologies (India) Private Limited, Pune vs. Deputy Commissioner of Income Tax
In the result, both the appeals of assessee are allowed as indicated above and the Stay Applications are dismissed
ITA 2847/PUN/2016[2012-13]Status: DisposedITAT Pune25 Apr 2018AY 2012-13
Bench: Ms. Sushma Chowla, Jm & Shri D. Karunakara Rao, Am आयकर अपीऱ सं. / Ita No.359/Pun/2016 यििाारण वषा / Assessment Year :2011-12
For Appellant: Shri Dhanesh BafnaFor Respondent: Shri Rajeev Kumar, CIT
Section 143(3)Section 271(1)(c)Section 92C
…was less than 25% as against employee cost of 47.75% of assessee. In this regard, the learned Authorized Representative for the assessee placed reliance on the ratio laid down by the Mumbai Bench of Tribunal in Goldman Sachs Services (P.) Ltd. Vs. ITO (2015) 69 SOT 28 (Mumbai – Trib.). In respect of second concern Universal Print Systems Ltd., the learned Authorized Representative for the assessee again pointed out that the said concern was also not comparable because of its low employee cost filter. He further pointed out that the Assessing Officer may verify the employee cost filter of the said concerns and if…