Case Law Details
PCIT Vs WSP Consultants India Pvt Ltd (Delhi High Court)
Introduction: The recent case of Principal Commissioner of Income Tax (PCIT) versus WSP Consultants India Pvt Ltd saw the Delhi High Court addressing critical transfer pricing issues for the Assessment Year 2012-13. The appellant, represented by the revenue authority, contested the Income Tax Appellate Tribunal’s (ITAT) order dated March 2023.
Background: WSP Consultants India Pvt Ltd, the respondent/assessee, filed its Return of Income for the relevant Assessment Year on November 30, 2012, declaring a loss of Rs. 5,58,25,905/-. The Transfer Pricing Officer (TPO), under Section 92CA of the Income Tax Act, 1961, proposed an upward adjustment of Rs. 4,76,89,336/- related to international transactions involving building design services.
After objections were raised before the Dispute Resolution Panel (DRP), a decision was rendered, reducing the adjustment to Rs. 4,26,08,980/-. The Assessing Officer (AO) then passed a final assessment order in line with the DRP’s directions. Subsequently, the respondent appealed to the Tribunal, which partly allowed their appeal.
Issues for Consideration: The appellant raised two main issues in the appeal:
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