Case Law Details
Willis Towers Watson India Pvt. Ltd. Vs ACIT (ITAT Delhi)
Introduction: In the case of Willis Towers Watson India Pvt. Ltd. vs. ACIT, heard by ITAT Delhi, the appellant contested an order issued by the Assessing Officer (AO) under the Income Tax Act, 1961, related to transfer pricing adjustments. The appeal raised various grounds, challenging the adjustments made by the tax authorities. This article delves into the details of the case, including the grounds of appeal, the facts, and the legal arguments presented by both sides.
Grounds of Appeal: The appellant raised multiple grounds challenging the AO’s order. These included disputing the correctness of the facts and legal principles considered, objections to the adjustment pertaining to the provision of consultancy services to associated enterprises (AEs), and issues related to the economic analysis undertaken by the appellant.
Background: The AO had proposed a total adjustment of INR 6,91,26,651 under section 92CA(3) of the Income Tax Act, 1961. The appellant had filed objections before the Dispute Resolution Panel (DRP), which issued directions. Despite the directions, the initial adjustment remained unchanged.
Appeal to ITAT: Subsequently, the appellant filed an appeal before the Income Tax Appellate Tribunal (ITAT). In their appeal, they highlighted that the Transfer Pricing Officer (TPO) did not follow the DRP’s directions in the Order Giving Effect (OGE).
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