ORDER 

PER SUDHANSHU SRIVASTAVA, JM:

This appeal is preferred by the assessee against the final assessment order dated 18.11.2015 passed u/s 144C of the Income Tax Act 1961 (hereinafter called ‘the Act’) subsequent to the directions of the Ld. Dispute Resolution Panel (DRP) vide directions dated 28.10.2015 for assessment year 2011-12.

2.0 The brief facts of the case are that the assessee company is a 100% subsidiary of SSP Limited, United Kingdom which is engaged in supply of software services industry worldwide. The assessee company was incorporated on 21st April 2004 as Sirius Financial Solutions India Pvt. Ltd. and subsequently its name was changed to SSP India Pvt. Ltd. on 31st January, 2008. The return of income was filed declaring income at Rs. NIL. Subsequently the case picked up for scrutiny through CASS. During the course of assessment proceedings it was noticed that during the year under consideration, the assessee had entered into international transaction with its Associated Enterprises (AE). A reference was made to the Ld. Transfer Pricing Officer (TPO) for determining the Arms Length Price (ALP). The Ld. TPO proposed an adjustment of Rs. 1,36,95,705/-. The draft assessme