HP INDIA SALES PRIVATE LIMITED ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX LTU , BANGALORE
In the result, the appeal filed by the assessee is partly allowed
ITA 524/BANG/2017[2012-13]Status: DisposedITAT Bangalore18 Aug 2022AY 2012-13
Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.524/Bang/2017 : Asst.Year 2012-2013 M/S.Hp India Sales Private The Joint Commissioner Of Limited (Formerly Known As Income-Tax, Ltu V. Bangalore. Hewlett-Packard India Sales Private Limited), 24 Salarpuria Area, Hosur Main Road, Adugodi Bangalore – 560 030. Pan : Aaacc9862F. (Appellant) (Respondent) Appellant By : Sri.Ajay Vohra, Senior Counsel / Sri. Neeraj Jain, Sri.Lalit Attal & Sri.Karon Dhanuka, Advoicates Respondent By : Sri.Harishchandra Naik, Cit-Dr Date Of Pronouncement : 18.08.2022 Date Of Hearing : 27.07.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 03.01.2017 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2012-2013. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company Engaged In Import Of Computer Peripherals From Its Associated Enterprises (Aes) For Sale In India & Also Rendered Certain Support Services. The Return Of Income For Assessment Year 2012-2013 Was Filed On 29.02.2012, Admitting Total Income Of Rs.544,61,99,276. The Return Was Revised On 25.03.2014
For Appellant: Sri.Ajay Vohra, Senior Counsel / Sri. Neeraj JainFor Respondent: Sri.Harishchandra Naik, CIT-DR
Section 143(2)Section 143(3)Section 144CSection 92BSection 92C
6. Aggrieved by the directions of the DRP, the assessee has raised this issue before the Tribunal. The learned AR submitted that Bright Line Test is not one of the prescribed methods under the transfer pricing provisions. In this context, the learned AR relied on the judgment of the Hon’ble
Delhi High Court in the case of Sony Ericsson
