ITAT BANGALORE BENCH ‘B’
Yodlee Infotech (P.) Ltd.
versus
Income-tax Officer, Ward 12(2), Bangalore
IT Appeal No. 1397 (Bang.) of 2010
[ASSESSMENT YEAR 2006-07]
Date of pronouncement – 15.02.2013
ORDER
Jason P. Boaz, Accountant Member
This appeal by the assessee is directed against the order of under section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (herein after referred to as ‘the Act’) passed by the Assessing Officer (viz., ITO, Ward 12(2), Bangalore) on 8.10.2010 in accordance with the directions of the Dispute Resolution Panel, (DRP), Bangalore under section 144C(5) r.w.s 144C (8) of the Act dt.22.9.2010. The Assessment Year involved is 2006-07.
2. The facts of the case, in brief, are as under :
2.1 The assessee, an Indian Company engaged in the business of providing software development support services to its holding company and associated enterprise (AE) Yodlee Inc., USA, filed its return of income for Assessment Year 2006-07 on 18.12.2006 declaring income of Rs. 1,00,072 after claiming deduction of Rs. 1,92,58,728 under section 10B of the Act. The return was processed under section 143(1) of the Act and the case was subsequently selected for scrutiny by issue of notice under section 143(2) of the Act. As the international transactions of the assessee reported in Form 3CEB exceeded Rs. 10 Crores, a reference under section 92CA(1) of the Act was made by the Assessing Officer to the Transfer Pricing Officer (TPO) on 30.12.2008 in respect of the following international transactions entered into by the assessee with its AEs :
