CARL ZEISS INDIA (BANGALORE) PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE
In the result, the appeal filed by the assessee stands partly allowed as indicated hereinabove
ITA 192/BANG/2022[2017-18]Status: DisposedITAT Bangalore16 Jun 2023AY 2017-18
Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuit(Tp)A No. 192/Bang/2022 Assessment Year : 2017-18 M/S. Carl Zeiss India (Bangalore) Pvt. Ltd., The Deputy Plot No. 3, Jigani Link Road, Commissioner Of Bommasandra Industrial Income Tax, Area, Circle 2 (1)(1), Bengaluru – 560 099. Vs. Bengaluru. Pan: Aadcc6152H Appellant Respondent : Shri Nageshwar Rao, Assessee By Advocate Revenue By : Ms. Neera Malhotra, Cit-Dr Date Of Hearing : 12-04-2023 Date Of Pronouncement : 16-06-2023 Order Per Beena Pillaipresent Appeal Is Filed By The Assessee Against Assessment Order Dated 25.01.2022 Passed By Nfac, Delhi For A.Y. 2017-18 On Following Grounds Of Appeal: “Based On The Facts & Circumstances Of The Case & In Law, Carl Zeiss India (Bangalore) Private Limited (Hereinafter Referred To As "Carl Zeiss India" Or "The Appellant"), Respectfully Craves Leave To Prefer An Appeal Against The Order Passed By The Additional / Joint / Deputy / Assistant Commissioner Of Income Tax/ Income- Tax Officer, National Faceless Center, Delhi (Hereinafter Referred To As "Ld. Assessing Officer" Or The "Ld. Ao"), Dated 25 January 2022 For The Assessment Year ("Ay")
For Respondent: Shri Nageshwar Rao
Section 143(3)Section 144BSection 144C(13)Section 144C(5)
Transfer Pricing) u/s 92CA(1) of the Act for the determination of Arms Length Price (ALP) for AY 2017-18. 4.2 The Ld.TPO on receipt of the reference called upon assessee to file requisite details in form 3CEB. The Ld.TPO noted that, the assessee provides after sales support services for Carl Zeiss products in India. The company caters to both
