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R.K.PANDA, N.V.VASUDEVAN
Trigent Software Ltd. – Appellant
Versus
Assistant Commissioner of Income-tax 5(3), Mumbai – Respondent
N.V. Vasudevan, Judicial Member - This is an appeal by the assessee against the order dated 1/9/2010 of the ACIT 5(3), Mumbai (hereinafter referred to as the AO) passed under section 143(3) of the Act r.w.s. 144C(13) of the Income Tax Act, 1961 (the Act). The grounds raised by the assessee in its appeal read as follows:
"1. On the facts & circumstances of the case the Learned Dispute Resolution Panel (DRP) has erred in directing the Assessing Officer to make addition of Rs. 1,71,28,081/- in compliance of Section 92C(4) of Income Tax Act, 1961. The appellant prays that the addition made of Rs. 1,71,28,081/- may be deleted.
2. On the facts and circumstances of the case the appellant prays that the DRP has not dealt with issues raised before them during the course of hearing and has arbitrarily rejected the claim of the appellant. This fact is evidence from the directions given by DRP. The appellant prays that the direction given by the DRP and followed by the Assessing Officer is contrary to provisions of law and the additions made may be deleted.
3. On the facts and circumstances of the case the appellant has established beyond iota of doubt that the Trigent Software Inc. (AE) h
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