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INCOME TAX APPELLATE TRIBUNAL (BANGALORE BENCH)
Prashant Maharishi, VP, Soundararaajan K., J
DECATHLON SPORTS INDIA PRIVATE LIMITED BANGALORE KARNATAKA – Appellant
Versus
DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE 2(2)(1) BENGALURU KARNATAKA – Respondent
| Table of Content |
|---|
| 1. assessment appeal specifics (Para 1 , 2) |
| 2. factual background of the case (Para 3 , 4 , 5 , 6) |
| 3. intra-group transactions overview (Para 10 , 11 , 12) |
| 4. court's view on expenditure claims (Para 36 , 46 , 59) |
| 5. final orders and conclusions (Para 60 , 62) |
ORDER
Per Prashant Maharishi, Vice President
1. This appeal is filed by Decathlon Sports India Private Limited (the Assessee or Appellant) for the Assessment year 2020-21 against the assessment order passed u/s. 143(3) r.w.s. 144(13) r.w.s. 144B of the Income-tax Act, 1961 (The Act) dated 29.07.2024 by the Assessment Unit [ The Ld. AO] wherein the total income of assessee was assessed at Rs. 155,34,29,950/- against the returned income of assessee at Rs. NIL. The assessment order is passed in pursuance of the order passed u/s. 92CA (3) by the DCIT (TP), 1(2)(1), [ The ld. TPO] dated 27.7.2023, consequent to directions of the ld. Dispute Resolution Panel, Bengaluru [ld. DRP] dated 20.6.2024 and consequent order giving effect passed by the ld. AO/TPO.
2. Assessee is aggrieved and has raised the following grounds of appeal: -
“General Ground:
1. The Ld. AO /TPO /DRP erred in determining and assessing the total income of t
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