EPSON INDIA PRIVATE LIMITED,ULSOOR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE
In the result, the appeal filed by the assessee stands partly allowed
ITA 206/BANG/2021[2016-17]Status: DisposedITAT Bangalore14 Jul 2022AY 2016-17
Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 206/Bang/2021 Assessment Year : 2016-17 M/S. Epson India Pvt. Ltd., The Deputy 12Th Floor, The Milenia, Commissioner Of Tower A, Income Tax, No. 1,Murphy Road, Circle 2 (1)(1), Ulsoor, Vs. Bangalore. Bangalore – 560 008. Pan: Aaace7858F Appellant Respondent : Shri Padamchand Khincha, Assessee By Ca : Dr. Manjunath Karkihalli, Revenue By Cit Dr Date Of Hearing : 15-06-2022 Date Of Pronouncement : 14-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 25/03/2021 Passed By National E-Assessment Centre, Delhi For A.Y. 2016-17 On Following Grounds Of Appeal: “General Ground 1. The Orders Passed By Learned Additional / Joint / Deputy / Assistant Commissioner Of Income Tax / Income- Tax Officer, National E-Assessment Centre (Hereinafter Referred As "Ao" For Brevity), Learned Deputy Commissioner Of Income Tax (Tp) — 1(2)(1), Bangalore (Hereinafter Referred As "Tpo" For Brevity) & The Honourable Drp-1
For Respondent: Shri Padamchand Khincha
transfer pricing analysis submitted by the Appellant.
(iii) Adopting inappropriate filters like persistent loss making, RPT filter etc. in the process of selecting comparables.
(iv) Selecting inappropriate comparables and selecting companies as comparables even though they are not comparable in terms of functions performed, assets utilized, risks assumed, size, have unusual business circumstances, high margin, etc. The lower income
