E-GAIN COMMUNICATIONS PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2),, PUNE
In the result, the appeal filed by the assessee stands partly allowed for statistical purposes
ITA 2675/PUN/2017[2013-14]Status: DisposedITAT Pune17 Jun 2022AY 2013-14
Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.2675/Pun/2017 िनधा"रण वष" / Assessment Year: 2013-14 E-Gain Communications Pvt. Vs. Dcit, Circle-1(2), Pune. Ltd., Office No.702, 7Th Floor, B-1, The Cerebrum It Park, Vadgaon Sheri, Kalyani Nagar, Pune- 411014. Pan : Aaacn9946R Appellant Respondent Assessee By : Shri Madhur Agarwal Revenue By Shri Arvind Desai : Date Of Hearing : 06.06.2022 Date Of Pronouncement : 17.06.2022 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)- 13, Pune. [‘The Cit(A)’] Dated 11.08.2017 For The Assessment Year 2013-14. 2. Briefly, The Facts Of The Case Are That The Appellant Is A Company Incorporated Under The Provisions Of The Companies Act, 1956. It Is Wholly Owned Subsidiary Of Egain Communication
For Appellant: Shri Madhur Agarwal
Section 10ASection 92C
method, but rejected the TP study report submitted by the assessee company and proceeded to identify the different set of comparable entities for the purpose of determining the ALP of the international transactions. While doing so, the TPO applied the following filters :-
S. No.
Criteria
(i)
Only current years data (FY 2012-13) has been used.
(ii)
Companies with income
