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R.S.SYAL, A.T.VARKEY
Birlasoft (India) Ltd. – Appellant
Versus
Deputy Commissioner of Income-tax, Circle-3 (1), New Delhi – Respondent
A.T. Varkey, Judicial Member - This is the first appeal preferred by the assessee against the assessment order dated 19.02.2014 passed by the AO under section 143(3) read with Section 144C of the Income Tax Act,, 1961 (herein after "the Act"),in pursuance to direction issued by after the Dispute Resolution Panel (DRP) for Assessment Year 2009-10.
2. Ground No. 1 is general in nature and it needs no adjudication inasmuch as all other grounds taken in the appeal shall take care of the additions made by the AO in the assessment order.
3. Now, we shall come to the ground No. 2 to 2.12 regarding the issue about Transfer Pricing Adjustment. In these ground, it has been alleged by the assessee that the Assessing Officer has erred in making adjustment of Rs. 34,25,12,827/- to the income of the assessee on account of the difference in the Arms length price of the international transactions undertaken by the assessee during the year under consideration. It has been further alleged that the Assessing Officer has erred on facts and in law in disregarding the internal bench marking undertaken by the assessee for determining the arm's length price of the international transactions applying TN
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