Fidelity Information Services India Private Limited, Punjab vs. Deputy Commissioner of Income Tax, Chandigarh
In the result, the appeal of the Revenue is dismissed
ITA 998/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh28 May 2025AY 2020-21
Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 998/Chd/2024 निर्धारण वर्ष / Assessment Year: 2020-21 Fidelity Information Services Vs The Dcit, Chandigarh, India Private Ltd., 2Nd A-45, Industrial Area, Sector 74, Phase 8B, Sas Nagar. स्थायी लेखा सं./Pan No: Aagcs0395D अपीलार्थी/Appellant प्रत्यर्थी/Respondent Assessee By: Shri Vishal Kalra, Advocate & Ms. Sumisha, Ca Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 06.05.2025 Date Of Pronouncement : 28.05.2025 Hybrid Hearing Order Per Raj Pal Yadav, Vp The Assessee Is In Appeal Before The Tribunal Against The Assessment Order Dated 31.07.2024 Passed U/S 143(3) Read With Section 144C(13)/144B Of The Income Tax Act In
For Appellant: Shri Vishal Kalra, Advocate & Ms. Sumisha, CAFor Respondent: Shri Manav Bansal, CIT DR
Section 139(1)Section 143(2)Section 143(3)Section 144C(13)Section 234ASection 270A
services to its customers
who happens to be an AE of the assessee, namely, ‘Fidelity
Information Services LLC, USA'. The assessee had an Advance
Pricing Agreement with the CBDT. The software development
services of the assessee provided at the respective places and
therefore, its employee has to undertake foreign travel ... mark up of 15% and since the additional mark up of
1.60% (over and above 15%) has been determined pursuant to the unilateral
Advance Pricing Agreement entered into with CBDT dated_6/02/2017, the
additional revenues of Rs 2,73,90,440/- has been offered as part of the modified
return
