UST GLOBAL TECHNOLOGY SERVICES (INDIA) PRIVATE LIMITED,KOCHI vs. DCIT,CORPORATE CIRCLE 2(1), KOCHI
In the result, appeal filed by the assessee stands partly allowed
ITA 1071/COCH/2024[2021-22]Status: DisposedITAT Cochin08 Sept 2025AY 2021-22
Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary
For Appellant: Respondent byFor Respondent: Shri Rajakannam, Advocate
Section 143Section 92C
Transfer Pricing
Officer (TPO) for the purpose of determination of ALP in respect of
the above international transaction.
4
The TPO vide order dated 09/10/2023 passed u/s. 92CA(3),
suggested the TP adjustment in respect of software development
agreement of Rs. 12,84,50,000/- and also interest on delayed
receivables of Rs. 5,97,26,729/- u/s. 92CA
