A.T. KEARNEY INDIA PVT. LTD. (INDIA BRANCH OFFICE),GURGAON vs. ACIT, NEW DELHI
In the result, the appeal of the assessee stands allowed in
ITA 2623/DEL/2015[2010-11]Status: DisposedITAT Delhi21 Jun 2019AY 2010-11
Bench: Shri N.S. Saini & Shri Sudhanshu Srivastavaassessment Year: 2010-11 A.T. Kearney India Pvt. Ltd. Acit, (India Branch Office), Circle 1(1), 6Th Floor, Tower D, New Delhi. Vs Global Business Park, Gurgaon-122002 (Pan: Aadca1436G) Appellant Respondent Assessee By: Shri Himanshu Sinha, Adv. Ms Vrinda Tulsiyan, Adv. Department By: Shri H.K. Choudhary, Cit Dr Ms Saweta Nakra, Sr. Dr Date Of Hearing : 14.06.2019 Date Of Pronouncement : 21.06.2019
For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri H.K. Choudhary, CIT DR
Section 10ASection 143(1)Section 143(3)Section 144CSection 92C
section 92C (4) of the Act would not be attracted on
the voluntary transfer pricing adjustment made by the assessee
and the provisions were to apply only in cases where the
adjustments had been made by the TPO/Assessing Officer. It
was submitted that since no transfer pricing adjustment has
survived, the deduction u/s 10A of the Act could