M/S PERSISTENT SYSTEMS LIMITED,PUNE vs. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, PUNE
In the result, appeal of the Assessee is Partly Allowed
ITA 692/PUN/2022[2018-19]Status: DisposedITAT Pune02 Nov 2023AY 2018-19
Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.692/Pun/2022 िनधा"रणवष" / Assessment Year : 2018-19 M/S.Persistent Systems Assessment Unit, Income Limited, V Tax Department. “Bhageerath” 402, Senapati S Bapat Road, Pune – 411016. Pan: Aabcp 1209 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Dhanesh Bafna& Shriaditya Vaidya– Ar’S Revenue By Shri Suhas Kulkarni - Irs Addl Commissioner Of Income Tax Date Of Hearing 26/09/2023 Date Of Pronouncement 02/11/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Assessment Order, Dated 20.07.2022 Under Section 143(3) R.W.S. 144C(13) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2018-19. The Assessee Has Raised The Following Grounds Of Appeal: “Ground 1: Order Is Invalid / Non Est On The Facts & In The Circumstances Of The Case & In Law, The Assessment Unit (‘Au’) Has Erred In Passing The Draft Assessment M/S.Persistent Systems Limited [A]
Section 143(3)Section 144Section 144(11)Section 144(7)Section 144BSection 144C(6)(C)
Transfer Pricing related grounds
Ground No. 2: General Ground
On the facts and in the circumstances of the case, and in law, the AU pursuant to the directions of the Ld. DRP, erred in making a TP
2
M/s.Persistent Systems Limited [A]
adjustment of INR 27,05,17,208 to the income of the Appellant, by holding that the Appellant
