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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
VIKAS AWASTHY, J, AVDHESH KUMAR MISHRA, AM
M/S AMADEUS INDIA PVT LTD NEW DELHI – Appellant
Versus
ASST.COMMISSIONER OF INCOME TAX CIRCLE 1(1) NEW DELHI DELHI – Respondent
| Table of Content |
|---|
| 1. overview of the appeal concerned for ay 2018-19. (Para 1 , 2) |
| 2. court's observation on disallowance under section 14a. (Para 3 , 7) |
| 3. arguments regarding the disallowance of advertising expenses. (Para 4) |
| 4. court's ruling on disallowance under section 14a. (Para 6) |
| 5. final decision on the appeal. (Para 10) |
ORDER
PER AVDHESH KUMAR MISHRA, AM
This appeal of the assessee for the Assessment Year (hereinafter, the ‘AY’) 2018-19 is filed against the order dated 27.05.2022 passed under section 143(3)/144C of the of the Income Tax Act, 1961 (hereinafter, the ‘Act’) by the Assistant Commissioner of Income Tax, Circle-1(1), Delhi [hereinafter, the ‘Assessing Officer’/ ‘AO’].
2. Vide 10 grounds, the issues raised in this appeal are as under: -
(i) Addition on account ALP adjustment for Advertising, Marketing and Sales Promotion Expenses (AMP) (Ground Nos. 1 to 8)
(ii) Disallowance of expenses under section 14A of the Act rwr 8D of the I. T. Rules (Ground Nos. 9 to 9.2)
(iii) Rejection of revised computation of income (Ground No. 10 & 10.1)
3. The brief facts giving rise to this appeal are that the assessee, engaged in the business of providing data processing and related services
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