COMMVAULT SYSTEMS INDIA PVT. LTD., HYDERABAD,HYDERABAD vs. DCIT, CIRCLE-1(2), HYDERABAD, HYDERABAD
Appeal is treated as allowed for statistical purposes
ITA 160/HYD/2017[2012-13]Status: DisposedITAT Hyderabad04 Sept 2020AY 2012-13
Bench: Smt. P. Madhavi Devi & Shri D.S. Sunder Singhassessment Year: 2012-13 M/S Commvault Systems Dcit, Circle 1(2) (India) Private Limited Vs. Hyderabad 5Th Floor, Plot No.39, Phase Ii Block A, Ananth Info Park Hitech City, Madhapur Hyderabad Pan: Aaccc3708L (Appellant) (Respondent) Sh. Ajeet Tolani Asessee By: Revenue By: Smt. Anjala Sahu, D.R. Date Of Hearing: 01/09/2020 Date Of Pronouncement: 04/09/2020 Order Per Smt. P. Madhavi Devi, J.M. This Is An Appeal Filed By The Assessee For The A.Y. 2012-13 Against The Final Assessment Order Dated 26.12.2016 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T. Act, 1961. 2. Brief Facts Of The Case Are That The Assessee Company, Engaged In The Business Of Software Development Services & Unified Data Storage Solutions, E-Filed Its Original Return Of Income For The A.Y. 2012-13 On 11.10.2012 Admitting Total Income Of
For Respondent: Smt. Anjala Sahu, D.R
Section 115Section 143(3)Section 92(3)Section 92C
section 92 of the I.T. Act to argue that where no income is chargeable to tax or it goes to increase the loss, then the TP proceedings are not applicable. He has also drawn our attention to the T.P study of the assessee and particularly, para 7 thereof, wherein the assessee has reported that the goods are supplied