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Section 92C3 Section 143(3)2 Section 144C(5)2

COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

ITA 1654/CHNY/2011[2007-08]Status: DisposedITAT Indore06 Oct 2023AY 2007-08

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2007-08 Computer Sciences Acit, Corporation India Private Company Circle 1(3), Limited, Chennai [Formerly Covansys (India) Private Limited], बनाम/ Unit 13, Block 2, Sdf Buildings, Vs. Madras Export Processing Zone, Tambaram, Chennai (Assessee / Appellant) (Revenue / Respondent) Pan: Aaacc1351M Assessee By Shri Neeraj Jain, Adv. Shri Abhishek Agrawal, Ca Revenue By Shri P.K. Mishra, Cit Dr Date Of Hearing 12.07.2023 Date Of Pronouncement

Section 10ASection 143(2)Section 143(3)Section 144C(5)Section 14ASection 92C

Transfer Pricing Officer (TPO). During proceeding, the TPO accepted (i) TNMM as ‘most appropriate method’, and (ii) OP/OC% as “PLI” for working of TNMM, as adopted by assessee. But he made certain modifications in the approach of assessee. He observed that the assessee-company was having 5 different units at different locations, namely (i) Bangalore Unit, (ii) Bangalore Strategic Business