M/S SUBEX LIMITED,BANGALORE vs. INCOME TAX OFFICER WARD-6(1)(4), BANGALORE
In the result, the appeal filed by the assessee stands partly allowed
ITA 107/BANG/2019[2014-15]Status: DisposedITAT Bangalore14 Jul 2022AY 2014-15
Bench: Smt. Beena Pillai & Shri. Laxmi Prasad Sahuit(Tp)A No. 107/Bang/2019 Assessment Year : 2014-15 M/S. Subex Ltd., Rmz Ecoworld, The Income Tax Outer Ring Road, Officer, Devarabisanahalli, Ward – 6 (1)(4), Bangalore – 560 103. Bangalore. Vs. Pan: Aabcs9255R Appellant Respondent Assessee By : Shri Ajay Rotti, Ca : Shri Sunil Kumar Singh, Cit- Revenue By Dr Date Of Hearing : 07-06-2022 Date Of Pronouncement : 14-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 26/10/2018 Passed By Ld.Ito, Ward – 6(1)(4), Bangalore For A.Y. 2014-15 On Following Grounds Of Appeal: “The Grounds Stated Hereunder Are Independent Of & Without Prejudice To One Another. The Appellant Submits As Under: 1. Assessment & Reference To Learned Transfer Pricing Officer Are Bad In Law 1.1. The Income Tax Officer. Ward — 6(1)(4), Bangalore (Learned Assessing Officer Or 'Ld. Ao') Erred In Making A Reference To The Deputy Commissioner Of Income-Tax, Transfer Pricing —Range 2(2)(1) (Learned Transfer Pricing Officer' Or 'Ld. Tpo'), Inter Alia, Since He Has Not Recorded
For Appellant: Shri Ajay Rotti, CA
Section 143(3)Section 144C(13)Section 92C(3)
gain has not been claimed in the computation of income and forms part of computing the margin as per transfer pricing provisions. The Ld.TPO is directed to consider the claim in accordance with the above view in assessee’s own case for A.Y. 2010-11 (supra).
10. Ground no. 6 is in respect of interest on trade receivables
