Capping of TP adjustments to combined group profits not possible

IN THE ITAT DELHI BENCH ‘I’ Interra Information Technologies (India) (P.) Ltd. Versus Deputy Commissioner of Income-tax, Circle 11(1), New Delhi IT APPEAL NOS. 5568 (DELHI) of 2010 and 5680 (DELHI) OF 2011 [ASSESSMENT YEARS 2006-07 & 2007-08] OCTOBER 31, 2012 ORDER J. Sudhakar Reddy, Accountant Member  These appeals filed by the assessee are directed against the order of the Assessing Officer passed under sec. 143(3) read with sec. 144C of the Income-tax Act, 1961 (the Act). 2. Facts in brief – Interra Information Technologies (India) Private Limited, a ...