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“cost plus method”

Transfer PricingSection 92CSection 92C204 judgments

The decision most relied on for cost plus method is CIT v. Cushman & Wakefield (India) (P.) Ltd. (367 ITR 730), cited in 120 judgments on BharatTax.

Leading authorities on cost plus method

CIT v. Cushman & Wakefield (India) (P.) Ltd.
367 ITR 730 · 2014 · High Court
120
citing judgments

This case determines the Arm's Length Price (ALP) for intra-group services and reimbursements, clarifying when charges constitute services warranting a mark-up versus mere pass-through costs. It provides guidance on the circumstances under which an ALP adjustment, including an ALP of 'nil', is appropriate for such transactions.

Asstt. CIT v. MSS India (P.) Ltd.
32 SOT 132 · 2009 · ITAT
26
citing judgments

The Comparable Uncontrolled Price (CUP) method is preferred when comparable transactions with third parties are available to determine if transfer prices are at arm's length. Transactional profit methods are considered methods of last resort.

Brigade Global Services Pvt. Ltd. v. ITO
33 Taxmann.com 618 · 2013 · ITAT
11
citing judgments

A company engaged in outsourced ITES activities can be excluded as a comparable if a significant portion of its activities were outsourced, resulting in an abnormally low employee cost.

Judgments citing cost plus method

Ipca Laboratories Ltd, Mumbai vs. Asst CIT (Ltu), Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2493/MUM/2015[2008-09]Status: DisposedITAT Mumbai29 Aug 2022AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

marginal different of 1.74% which is within the permissible range of +/- 5%. The learned Transfer Pricing Officer rejected the CUP method but applied cost plus method and proposed the adjustment. The learned CIT (A) examined the transaction and upheld the CUP method. It is examined that assessee has sold Pacimol ... Pharmaceutical products by National Drugs (Pty) Ltd, it adopted CUP method and for sale of pharmaceuticals products to Activa Pharmaceutical it adopted cost plus method. With respect to the purchase of pharmaceutical products, the learned Assessing Officer accepted the benchmarking by the assessee and made no adjustment. With respect

Ipca Laboratories Ltd, Mumbai vs. DCIT (Ltu), Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3267/MUM/2012[2007-08]Status: DisposedITAT Mumbai29 Aug 2022AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

marginal different of 1.74% which is within the permissible range of +/- 5%. The learned Transfer Pricing Officer rejected the CUP method but applied cost plus method and proposed the adjustment. The learned CIT (A) examined the transaction and upheld the CUP method. It is examined that assessee has sold Pacimol ... Pharmaceutical products by National Drugs (Pty) Ltd, it adopted CUP method and for sale of pharmaceuticals products to Activa Pharmaceutical it adopted cost plus method. With respect to the purchase of pharmaceutical products, the learned Assessing Officer accepted the benchmarking by the assessee and made no adjustment. With respect

Ipca Laboratories Ltd, Mumbai vs. ACIT (Ltu), Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8120/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

marginal different of 1.74% which is within the permissible range of +/- 5%. The learned Transfer Pricing Officer rejected the CUP method but applied cost plus method and proposed the adjustment. The learned CIT (A) examined the transaction and upheld the CUP method. It is examined that assessee has sold Pacimol ... Pharmaceutical products by National Drugs (Pty) Ltd, it adopted CUP method and for sale of pharmaceuticals products to Activa Pharmaceutical it adopted cost plus method. With respect to the purchase of pharmaceutical products, the learned Assessing Officer accepted the benchmarking by the assessee and made no adjustment. With respect

Ipca Laboratories Ltd, Mumbai vs. DCIT (Ltu), Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8084/MUM/2010[2006-07]Status: DisposedITAT Mumbai29 Aug 2022AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

marginal different of 1.74% which is within the permissible range of +/- 5%. The learned Transfer Pricing Officer rejected the CUP method but applied cost plus method and proposed the adjustment. The learned CIT (A) examined the transaction and upheld the CUP method. It is examined that assessee has sold Pacimol ... Pharmaceutical products by National Drugs (Pty) Ltd, it adopted CUP method and for sale of pharmaceuticals products to Activa Pharmaceutical it adopted cost plus method. With respect to the purchase of pharmaceutical products, the learned Assessing Officer accepted the benchmarking by the assessee and made no adjustment. With respect

ACIT Cen Cir 13, Mumbai vs. Ipca Laboratories Ltd, Mumbai

In the result, appeal filed by the learned assessing officer is dismissed

ITA 7511/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

marginal different of 1.74% which is within the permissible range of +/- 5%. The learned Transfer Pricing Officer rejected the CUP method but applied cost plus method and proposed the adjustment. The learned CIT (A) examined the transaction and upheld the CUP method. It is examined that assessee has sold Pacimol ... Pharmaceutical products by National Drugs (Pty) Ltd, it adopted CUP method and for sale of pharmaceuticals products to Activa Pharmaceutical it adopted cost plus method. With respect to the purchase of pharmaceutical products, the learned Assessing Officer accepted the benchmarking by the assessee and made no adjustment. With respect

DCIT, Cir-6(2)(2), Mumbai vs. Diageo India Pvt.Ltd., Mumbai

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

ITA 2858/MUM/2016[2011-12]Status: DisposedITAT Mumbai25 Aug 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Diageo India P. Ltd. Dcit 4Th Floor, Nicholas Piramal Tower Rg 6(2)(2) Peninsula Corporate Park, Aayakar Bhavan, Vs. Ganpatrao Kadam Marg, Mk Road, Lower Parel, Mumbai-400 020 Mumbai-400 013 (Appellant) (Respondent) Pan No. Aaaci 3378 L Diageo India P. Ltd. Dcit 4Th Floor, Nicholas Piramal Tower Rg 6(2)(2) Peninsula Corporate Park, Aayakar Bhavan, Vs. Ganpatrao Kadam Marg, Mk Road, Lower Parel, Mumbai-400 020 Mumbai-400 013 (Appellant) (Respondent)

For Appellant: Shri Nishant Thakkar &For Respondent: Ms. Vatsalaa Jha, CIT DR
Section 143(3)Section 144C(13)Section 253Section 92BSection 92C

Paras 121& 194(xi)] ; In separately determining the ALP of AMP expenses, the TPO is free to choose any other suitable method including Cost plus method [Para 194(xiii)]; ITA no.1002&2858/Mum/2016 Diageo India Private Limited; A.Y. 11–12 In so making a TP adjustment on account of AMP expenses

Diageo India P.Ltd, Mumbai vs. DCIT RG 6(2)(2), Mumbai

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

ITA 1002/MUM/2016[2011-12]Status: DisposedITAT Mumbai25 Aug 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Diageo India P. Ltd. Dcit 4Th Floor, Nicholas Piramal Tower Rg 6(2)(2) Peninsula Corporate Park, Aayakar Bhavan, Vs. Ganpatrao Kadam Marg, Mk Road, Lower Parel, Mumbai-400 020 Mumbai-400 013 (Appellant) (Respondent) Pan No. Aaaci 3378 L Diageo India P. Ltd. Dcit 4Th Floor, Nicholas Piramal Tower Rg 6(2)(2) Peninsula Corporate Park, Aayakar Bhavan, Vs. Ganpatrao Kadam Marg, Mk Road, Lower Parel, Mumbai-400 020 Mumbai-400 013 (Appellant) (Respondent)

For Appellant: Shri Nishant Thakkar &For Respondent: Ms. Vatsalaa Jha, CIT DR
Section 143(3)Section 144C(13)Section 253Section 92BSection 92C

Paras 121& 194(xi)] ; In separately determining the ALP of AMP expenses, the TPO is free to choose any other suitable method including Cost plus method [Para 194(xiii)]; ITA no.1002&2858/Mum/2016 Diageo India Private Limited; A.Y. 11–12 In so making a TP adjustment on account of AMP expenses

Citrix R & D India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 2(1)(1), Bangalore

In the result, the appeal filed by the assessee stands allowed partly as indicated herein above

ITA 220/BANG/2021[2016-17`]Status: DisposedITAT Bangalore25 Aug 2022

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 220/Bang/2021 Assessment Year : 2016-17 M/S. Citrix R&D India Pvt. Ltd., The Deputy Prestige Dynasty, Commissioner Of Ground Floor, Income Tax, 33/2, Ulsoor Road, Circle – 2(1)(1), Bangalore – 560042. Vs. Bangalore. Pan: Aabcn3639C Appellant Respondent Assessee By : Shri Sumit Khurana, Ca Revenue By : Shri M. Mathivanan, Cit-Dr Date Of Hearing : 04-07-2022 Date Of Pronouncement : 25-08-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Assessment Order Dated 30/03/2021 Passed By The National E-Assessment Centre, Delhi Relating To Assessment Year 2016-17 On Following Grounds Of Appeal: “The Grounds Mentioned Herein By The Appellant Are Without Prejudice To One Another. 1. That The Order Passed By The Learned Ao To The Extent Prejudicial To The Appellant, Is Bad In Law & Liable To Be Quashed. Transfer Pricing - 2. That The National E-Assessment Centre, Delhi / Deputy Commissioner Of Income Tax, Circle 2(1)(1), Bangalore ("Assessing Officer" Or "Learned Ao") & The Dispute Resolution Panel - 1 ("Learned Panel" Or "Learned Drp")

For Appellant: Shri Sumit Khurana, CAFor Respondent: Shri M. Mathivanan, CIT-DR

onwards). These amended provisions are applicable only when the determination of 'ALP' is done under the MAM being resale price method ('RPM'), cost plus method ('CPM') or transactional net margin method ('TNMM'). The relevant provisions of Rule 10CA of the Rules, in so far as it relates to choice

M/S Quicklogic Software (India) Pvt. Ltd., Bangalore vs. Deputy Commissioner of Income-Tax, Circle-3(1)(1), Bengaluru

In the result, the appeal filed by the assessee stands partly allowed

ITA 181/BANG/2022[2017-18]Status: DisposedITAT Bangalore27 Jul 2022AY 2017-18

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 181/Bang/2022 Assessment Year : 2017-18 M/S. Quicklogic Software (India) Pvt. Ltd., No. 10 Brindavan, The Deputy 3Rd Floor, Commissioner Of Yashoda Nagar Main Income Tax, Road, Circle 3(1)(1), Jakkur Plantation, Vs. Bangalore. Bengaluru – 560 064. Pan: Aaacq0656P Appellant Respondent Assessee By : Shri Mahaveer C Jain, Ca : Shri Sumer Singh Meena Cit Revenue By Dr Date Of Hearing : 12-07-2022 Date Of Pronouncement : 27-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 25/01/2022 By The National Faceless Assessment Centre For A.Y. 2017-18 On Following Revised Grounds Of Appeal:

For Appellant: Shri Mahaveer C Jain, CA
Section 142(1)Section 143(2)Section 92C

onwards). These amended provisions are applicable only when the determination of 'ALP' is done under the MAM being resale price method ('RPM'), cost plus method ('CPM') or transactional net margin method ('TNMM'). The relevant provisions of Rule 10CA of the Rules, in so far as it relates to choice

M/S. Sulzer Tech India P. Ltd., Navi Mumbai vs. Addl./Jt./ Dy./ Asstt. CIT/ Income Tax Officer, Delhi

In the result, appeal by the assessee is partly allowed for statistical purpose

ITA 633/MUM/2021[2016-17]Status: DisposedITAT Mumbai25 Jul 2022AY 2016-17

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Ravi Saeana a/wFor Respondent: Shri Tejinder Pal Singh
Section 143(3)Section 144C(13)Section 92CSection 92C(1)

aforesaid associated enterprise for availing such IT support services. For benchmarking, the associated enterprise was considered as tested party. Further, Cost Plus Method was selected as the most appropriate method with PLI of operating profit to total expenses. Accordingly, assessee selected 68 comparables from both APAC and EU regions, whose

Liebherr India P.Ltd, Navi Mumbai vs. Asst CIT 15(2)(1), Mumbai

In the result, appeal filed by the Appellant is partly allowed

ITA 2169/MUM/2017[2012-13]Status: DisposedITAT Mumbai28 Jun 2022AY 2012-13
For Appellant: Shri Ketan VedFor Respondent: Shri Michael Jerald
Section 143(3)Section 144C(13)Section 144C(5)

years. In earlier years the transaction pertaining to commission segment, service segment and trading segment were benchmarked using Comparable Uncontrolled Price Method (CUP), Cost Plus Method (CPM) and Resale Price Method (RPM), respectively. However, for the Assessment Year 2012-13, the Appellant had adopted aggregation approach and determined

M/S. Himalaya Wellness Company (Formerly Known As the Himalaya Drug Company), Bengaluru vs. The Deputy Commissioner of Income Tax, Circle- 6(1)(1), Bengaluru

In the result, the appeal filed by the assessee is partly allowed for statistical purpose

ITA 259/BANG/2022[2017-18]Status: DisposedITAT Bangalore14 Jun 2022AY 2017-18

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.259/Bang/2022 : Asst.Year 2017-2018 M/S.Himalaya Wellness Company The Deputy Commissioner Of (Formerly Known As The Himalaya Income-Tax, Circle 6(1)(1) V. Bengaluru. Drug Company), Makali, Tumkur Road Bengaluru – 562 162. Pan : Aadft3025B. (Appellant) (Respondent)

For Appellant: Sri.Padamchand Kincha, CAFor Respondent: Sri.Sumer Singh Meena, CIT -DR
Section 143(1)Section 143(2)Section 143(3)Section 144C(5)Section 2(11)Section 92C

ordinate bench referred above, we reject these grounds. 21. The ground numbers 7.7 to 8.4 relates to the adoption of "Cost Plus Method" as most appropriate method by the TPO and consequent transfer pricing adjustment made by him, which were confirmed by Ld. DRP. Identical issues were considered ... such persons OR such other relevant factors as the Board may prescribe, viz., (i) Comparable Uncontrolled Price Method; (ii) Resale Price Method; (iii) Cost Plus Method; (iv) Profit Split Method; (v) Transactional Net Margin Method; (vi) Such other method as may be prescribed by the Board. Sub-section

Enstage Software Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

The appeal of the assessee is partly allowed

ITA 260/BANG/2021[2016-17]Status: DisposedITAT Bangalore13 Jun 2022AY 2016-17

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(Tp)A No.260/Bang/2021 Assessment Year : 2016-17 M/S. Enstage Software Private Limited, Dcit (Exemptions), Vs. 16/1, Wings, 2Nd Floor, Circle – 2(1)(1), Cambridge Road, Halsuru, Bengaluru. Bengaluru – 560 008. Pan : Aaace 9963 B Appellant Respondent

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Smt. Susan Dolores George, CIT(OSD)(DR)(ITAT), Bengaluru
Section 143(3)Section 92(1)Section 92B(1)Section 92C

onwards). These amended provisions are applicable only when the determination of ‘ALP’ is done under the MAM being resale price method (‘RPM’), cost plus method (‘CPM’) or transactional net margin method (‘TNMM’). The relevant provisions of Rule 10CA of the Rules, in so far as it relates to choice

Dow Chemicals International Pvt Ltd. As Successor of Rohm and Haas (India) Pvt Ltd, Mumbai vs. ITO 14 (1)(3), Mumbai

In the result, the appeal of the assessee is allowed partly for statistical purposes

ITA 7936/MUM/2019[2015-16]Status: DisposedITAT Mumbai19 May 2022AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2015-16 Dow Chemical International Private Income Tax Officer-14(1)(3), Limited As Successor Of Rohm & Hass Room No. 458, 4Th Floor, (India) Private Limited, Vs. Aayakar Bhavan, M.K. Road, Godrej It Park-P2, 1St Floor Block B, 02, Mumbai-400020. Lbs Road, Godrej Business District, Pirojshanagar, Vikhroli (West), Mumbai-400079. Pan No. Aaacr 2855 F Appellant Respondent

For Appellant: Mr. Rajan R. Vora/For Respondent: Dr. Yogesh Kamat, CIT-DR
Section 92C

basis of IN 23,54,22,466 on the international transaction of import of raw materials from Associated Enterprises ('AEs'). Inappropriate rejection of Cost-Plus Method ('PM') and instead adopting Transactional Net Margin Method ('TNMM') as most appropriate method ('MAM') 3. erred in not accepting the economic analysis undertaken ... said list i.e. purchase of raw material and sale of finished goods amounting to ₹294.30 crores. The assessee adopted Cost Plus Method (CPM) taking profit level indicator (PLI) as gross profit/sales and gross profit was arrived after considering direct and indirect cost of production. The assessee worked

M/S. Ocwen Financial Solutions Private Limited, Bengaluru vs. Joint Commissioner of Income Tax, Special Range - 5, Bangalore

In the result appeal filed by the assessee stands partly allowed

ITA 2411/BANG/2019[2015-16]Status: DisposedITAT Bangalore13 May 2022AY 2015-16

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 2411/Bang/2019 Assessment Year : 2015-16 M/S. Ocwen Financial Solutions Pvt. Ltd., Pritech Park, Block 12, The Joint Commissioner Unit 2, 5B & 6A Floors, Of Income-Tax, Bellandur Village, Special Range-5, Sarjapur Marathahalli Bangalore. Ring Road, Vs. Bangalore – 560 103. Pan: Aaaco3764E Appellant Respondent : Shri K.R. Vasudevan & Assessee By Ms. Rashmi, Advocates : Dr. Manjunath Karkihalli, Revenue By Cit-Dr Date Of Hearing : 02-03-2022 Date Of Pronouncement : 13-05-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 24/09/2019 Passed By The Ld.Jcit, Special Range-5, Bangalore Under Section 143 (3) R.W.S 144C (13) Of The Act, For Assessment Year 2015-16 On Following Grounds Of Appeal: “I. Transfer Pricing The Grounds Mentioned Hereinafter Are Without Prejudice To One Another.

For Respondent: Shri K.R. Vasudevan &
Section 133(6)Section 143Section 92C

2411/Bang/2019 recruitment related costs are considered as operating costs and form part of the cost base that is compensated on cost plus method. Therefore, OMS also relatively bears the risk of attrition of manpower. Idle Capacity Risk This risk relates to non utilization or under-utilization of the resources

Xchanging Solutions Limited, Bangalore vs. The Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, grounds 20 to 23 are allowed for statistical purposes

ITA 294/BANG/2021[2016-17]Status: DisposedITAT Bangalore12 May 2022AY 2016-17
For Appellant: Sri.Padamchand Kincha, CAFor Respondent: Dr.Manjunath Karkaihalli, CIT-DR
Section 139(1)Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 40

onwards). These amended provisions are applicable only when the determination of ‘ALP’ is done under the MAM being resale price method (‘RPM’), cost plus method (‘CPM’) or transactional net margin method (‘TNMM’). The relevant provisions of Rule 10CA of the Rules, in so far as it relates to choice

M/S. Steer Engineering Pvt. Ltd., Bengaluru vs. Deputy Commissioner of Income-Tax, Circle-6(1)(2), Bengaluru

In the result, appeal of the Assessee is partly allowed

ITA 2071/BANG/2018[2012-13]Status: DisposedITAT Bangalore27 Apr 2022AY 2012-13

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathyassessment Year : 2012-13 M/S. Steer Engineering Private Limited, Vs. Dcit, No.290, 4Th Main, 4Th Phase, Circle – 6(1)(2), Peenya Industrial Area, Nagawara, Bengaluru. Bengaluru – 560 058. Pan : Aabcs 8840 E Appellant Respondent Assessee By : Shri. Narendra Jain, Advocate Revenue By : Mrs. Susan D. George, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 18.04.2022 Date Of Pronouncement : 27.04.2022

For Appellant: Shri. Narendra Jain, AdvocateFor Respondent: Mrs. Susan D. George, CIT(DR)(ITAT), Bengaluru
Section 144CSection 92(1)Section 92ASection 92A(1)Section 92CSection 92C(2)Section 92F

such other relevant factors as the Board may prescribed, namely :— (a) comparable uncontrolled price method (CUP);(b) resale price method;(RSPM)(c) cost plus method;(CPM)(d) profit split method;(PSM)(e) transactional net margin method(TNMM);(f) such other method as may be prescribed by the Board. By virtue

Ghetai Exports (India) Pvt. Ltd., Mumbai vs. ITO, WD. 9(1)(4), Mumbai

In the result, appeal of the assessee is allowed for statistical purposes

ITA 3172/MUM/2018[2010-11]Status: DisposedITAT Mumbai25 Apr 2022AY 2010-11

Bench: Infinity Mall Bhawan, Churchgate Malad (W), Mumbai-400064 Mumbai – 400 020 Pan/Gir No. Aaccg3494K (Appellant) .. (Respondent)

Section 143(3)

made export of trading items to the tune of Rs. 1,87,65,715/-. The assessee had benchmarked this international transaction by using Cost Plus Method (CPM) as the Most Appropriate Method (MAM). The ld. AO observed that Cost Plus Method could be applied only in respect of assessee engaged

M/S. Transworld Ict Solutions (P) Ltd., Bangalore vs. DCIT, Bangalore

In the result, both the appeals are partly allowed

ITA 1310/BANG/2010[2007-08]Status: DisposedITAT Bangalore22 Mar 2022AY 2007-08

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A Nos.1309 & 1310/Bang/2010 Assessment Years : 2006-07 & 2007-08 M/S. Transworld Ict Solutions Pvt. Ltd., Vs. Dcit, Innovator, No.15, Hoody, Whitefield Road, Circle – 2(1), Mahadevapura Post, Bengaluru. Bengaluru – 560 048. Pan : Aabct 3824 F Assessee Respondent Assessee By : Shri. G. S. Prashanth, Ca Revenue By : Shri. Dilip, Advocate, Standing Counsel For Department Date Of Hearing : 17.03.2022 Date Of Pronouncement : 22.03.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. G. S. Prashanth, CAFor Respondent: Shri. Dilip, Advocate, Standing Counsel for Department
Section 132Section 143(3)Section 153ASection 92Section 92(1)Section 92B(1)

direction of the DRP, the assessee has preferred the present appeal before the Tribunal. 57. It was submitted that the assessee was following cost plus method in its billing operation and consequently has added the cost of all back-office employees and claimed the amount from the principal. Thus, there

M/S. Transworld Ict Solutions (P) Ltd., Bangalore vs. DCIT, Bangalore

In the result, both the appeals are partly allowed

ITA 1309/BANG/2010[2006-07]Status: DisposedITAT Bangalore22 Mar 2022AY 2006-07

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A Nos.1309 & 1310/Bang/2010 Assessment Years : 2006-07 & 2007-08 M/S. Transworld Ict Solutions Pvt. Ltd., Vs. Dcit, Innovator, No.15, Hoody, Whitefield Road, Circle – 2(1), Mahadevapura Post, Bengaluru. Bengaluru – 560 048. Pan : Aabct 3824 F Assessee Respondent Assessee By : Shri. G. S. Prashanth, Ca Revenue By : Shri. Dilip, Advocate, Standing Counsel For Department Date Of Hearing : 17.03.2022 Date Of Pronouncement : 22.03.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. G. S. Prashanth, CAFor Respondent: Shri. Dilip, Advocate, Standing Counsel for Department
Section 132Section 143(3)Section 153ASection 92Section 92(1)Section 92B(1)

direction of the DRP, the assessee has preferred the present appeal before the Tribunal. 57. It was submitted that the assessee was following cost plus method in its billing operation and consequently has added the cost of all back-office employees and claimed the amount from the principal. Thus, there