Case Law Details
Capgemini India Pvt. Ltd. Vs DCIT (ITAT Mumbai)
Facts- Assessee filed its return of income on 7 October 2010 declaring income of ₹113,19,82,875/-. As the assessee has entered into several international transactions, reference was made to the Learned Additional Commissioner of Income-Tax, Transfer Pricing, 1(3), Mumbai for determination of arm’s length price of those transactions.
The draft assessment order was passed on 13th March, 2014 where several additions were made and total income was determined at ₹144,06,06,540/-.
Assessee did not file any objection before the learned DRP against the draft assessment order and therefore final assessment order under section 143(3) read with section 144C(13) of the Act was passed on 26th May, 2014. Learned AO over and above the transfer pricing adjustment made various other additions.
The assessee aggrieved with the above order-preferred appeal before the learned CIT (A), who passed an order on 8 February 2016 allowing the appeal of the assessee partly. Therefore, the assessee is aggrieved with that order and has preferred this appeal raising several grounds as per grounds of appeal. Some are highlighted here –
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