M/S SHINDENGEN INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE
In the result, the appeal is treated as allowed for statistical purpose
ITA 3343/BANG/2018[2014-15]Status: DisposedITAT Bangalore31 Aug 2021AY 2014-15
Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.3343/Bang/2018 Assessment Year : 2014-15 M/S. Shindengen India Pvt. Ltd., Vs. The Deputy Commissioner Of Income Tax, Plot No.283/2, Bommasandra Jigani Link Circle -6(1)(1), Road, Bengaluru – 560 105. Bengaluru. Pan : Aarcs 8947 E Appellant Respondent Appellant By : Shri. S. D. Kapila, Advocate Respondent By : Shri. Pradeep Kumar, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 30.08.2021 Date Of Pronouncement : 31.08.2021 O R D E R Per Chandra Poojarithis Is An Appeal By The Assessee Against The Order Dated 16.10.2018 Passed By The Dcit, Circle 6-(1)(1), Bengaluru, U/S.143(3) Read With Sec.144C (13) Of The Income Tax Act, 1961 (Act), In Relation To Ay 2014-15. 2. The First Issue That Arises For Consideration In This Appeal Is With Regard To The Addition Made To The Total Income Of The Assessee Of A Sum Of Rs.21,61,37,271 Being An Addition Made Consequent To Determination Of Arm’S Length Price (Alp) U/S.92 Of The Act, In Respect Of An International Transaction Entered Into By The Assessee With Its Associated Enterprise (Ae). The Assessee Is A Wholly Owned Subsidiary Of Shindengen Electric Mfg Co., Ltd, Japan. It Was Incorporated In India On August 21, 2012 Under The Indian
For Appellant: Shri. S. D. Kapila, AdvocateFor Respondent: Shri. Pradeep Kumar, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144CSection 92Section 92C
35A besides submissions dated
IT(TP)A No.3343/Bang/2018
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4.7.2018 copy of which are at pages 483 to 517 of assessee’s paper book.
The argument of the assessee on application of CUP method by the TPO was that CUPM compares the price charged' property transferred in a controlled transaction to the price charged for property transferred
