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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
SHRI SHAMIM YAHYA, ACJ, SHRI ANUBHAV SHARMA, J
American Express Services India Ltd. – Appellant
Versus
DCIT, Circle 1 (1), Metropolitan Saket, New Delhi. – Respondent
| Table of Content |
|---|
| 1. appeal against assessment orders for two assessment years. (Para 1 , 3 , 4) |
| 2. arguments regarding errors in selection of comparables and benchmarking. (Para 5 , 6 , 10) |
| 3. court observations on necessity for correct application of tax regulations. (Para 7 , 9) |
ORDER
PER SHAMIM YAHYA, ACCOUNTANT MEMBER :
The aforesaid appeals filed by the assessee are directed against the respective orders of the Assessing Officer pursuant to the directions issued by the ld. DR for the respective assessment years.
2. Since the issues are common & connected and the appeals were heard together, these are being consolidated and disposed off by this common order.
3. Grounds of appeal taken by the assessee read as under :-
“ASSESSMENT YEAR 2005-06
1. The order passed by the Learned Additional Director of Income Tax, Transfer Pricing Officer- 1 (1), New Delhi ("the Learned TPO"), final assessment order passed by the Deputy Commissioner of Income Tax, Circle 1(1), New Delhi (“the learned AO”) and the order passed by Hon'ble Commissioner of Income Tax (Appeals) - XX, New Delhi ("CIT(A)"), are bad in law and void- ab-initio.
2. The Hon'ble CIT(A) following the order of the learned TPO and AO has er
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