ADIENT INDIA PVT.LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(1),, PUNE
In the result, the appeal is allowed for statistical purposes
ITA 2986/PUN/2017[2013-14]Status: DisposedITAT Pune31 May 2021AY 2013-14
Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviनिर्धारण वषा / Assessment Year : 2013-14 Adient India Private Limited Vs. Dcit, Plot No.1, S No.235 & 245, Circle-1(1), Pune Hinjewadi, Tal-Mulshi, Pune - 411057 Pan : Aaact6342D Appellant Respondent Assessee By Shri Dhanesh Bafna Revenue By S/Shri Kalika Singh & Madhavan A.M. Krishnan Date Of Hearing 27-05-2021 Date Of Pronouncement 31-05-2021 आदेश / Order Per R.S.Syal, Vp : This Appeal By The Assessee Is Directed Against The Final Assessment Order Dated 27-10-2017 Passed By The Assessing Officer (Ao) U/S.143(3) Read With Section 144C(13) Of The Income-Tax Act, 1961 (Hereinafter Also Called ‗The Act‘) In Relation To The Assessment Year 2013-14. 2. The Only Issue Raised In This Appeal Is Against Transfer Pricing Addition Of Rs.5,95,39,429. Succinctly, The Factual Matrix Of The Case Is That The Assessee Was Earlier A 50:50 Joint
Section 143(3)Section 144C(13)
transfer pricing provisions under Chapter X of the Act w.e.f.
1.4.2013. The term `SDT‘ has been defined u/s 92BA to
include, inter alia, any expenditure in respect of which payment has been made or is to be made to a person referred to in section 40A(2)(b