M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM
In the result, the appeal for assessment year 2011-2012
ITA 475/COCH/2016[2012-13]Status: DisposedITAT Cochin11 May 2018AY 2012-13
Bench: Shri Chandra Poojari, Am & Shri George George K, Jm
For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)
method.
6.5 The TPO/ AO erroneously concluded that no services were received by the assessee, without appreciating the business realities of the Company and the evidences provided during the course of the TP assessment.
6.6 TPO / AO has ignored the fact that 92.31 % of the revenue was earned on account of the client services by USTRPL who has customer relationship
