BLACKROCK SERVICES INDIA PRIVATE LIMITED,GURGAON vs. INCOME TAX OFFICER, GURGAON
The appeal of the assessee is allowed
ITA 1671/DEL/2015[2010-11]Status: DisposedITAT Delhi06 May 2019AY 2010-11
Bench: Shri H. S. Sidhu & Shri Prashant Maharishiblack Rock Services India Private Vs. The Income Tax Officer, 5Th Floor, Hsidc Building Vanijya Limited, 3Rd Floor, Rolta Corporate Towers, 187, Nikunj, Udyog Vihar, Phase-V, Phase-I, Udyog Vihar, Gurgaon Gurgaon Pan: Aabch4449Q (Appellant) (Respondent) Black Rock Services India Private The Assistant Commissioner Of Vs. Limited, Income Tax , 3Rd Floor, Rolta Corporate Towers, 187, Circle-1(1), Phase-I, Udyog Vihar, Gurgaon Gurgaon Pan: Aabch4449Q (Appellant) (Respondent)
For Appellant: Shri K. M. Gupta, AdvFor Respondent: Shri Sandeep Kr. Mishra, Sr. DR
Section 143Section 144CSection 92Section 92CSection 92D
Transfer Pricing („TP‟) documentation maintained by the Appellant under section 92D of the Act and Rule 10D of the Rules and disregarding the arm‟s length price („ALP‟) as determined by the Appellant in the TP documentation;
2.3
disregarding the fact that the Appellant is a captive IT enabled service provider which does not bear substantial risks associated with
