M/S.IBS SOFTWARE SERVICES P. LTD,TRIVANDRUM vs. THE DCIT, TRIVANDRUM
ITA 601/COCH/2017[2013-14]Status: DisposedITAT Cochin13 Nov 2025AY 2013-14
Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)
For Appellant: Shri Rajakannan, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144CSection 144C(5)Section 36(1)(iii)Section 36(1)(va)Section 92C
transfer pricing adjustment in relation to notional interest on (a) loans/advances to AEs, and (b) receivables outstanding from AEs. Ground No. 3 to 7
read as under:
3
Assessment Year 2013-2014
“Imputation of notional interest
“3. On the facts and circumstances of the case and in law, the learned
AO erred in making and adjustment of INR.292,487,928
