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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
SHRI S.RIFAUR RAHMAN, ACM, SHRI SUDHIR PAREEK, JM
DCIT – Appellant
Versus
M/s. Koya and Company Construction Ltd. – Respondent
ORDER
PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :
1. The Revenue has filed appeal against the order of the Learned Commissioner of Income-tax (Appeals)-27, Delhi [“Ld. CIT(A)”, for short] dated 22.05.2023 for the Assessment Year 2017-18.
2. Brief facts of the case are, the assessee is a company limited by shares is specialized in the manufacture and execution of Infrastructure projects on contract basis and specialize in medium and large diameter turnkey pipeline contracts and allied Civil work.
3. During the financial year ended March 31, 2017, relevant to the assessment year 2017-18, the assessee had entered into the following specified domestic transactions :-
| S.No | Name of the Associated enterprise for the purpose of specified domestic Transaction | Description of the Transactions | Amount (Rs.) |
| 1 2 3 4 | Megha Engineering and Infrastructure Limited('MEIL') | Contract receipts | 28,08,43,152 |
| Sub-contract payments | 4,65,41,19,269 | ||
| Recoveries of materials and services | 9,63,16,438 | ||
| Purchase of goods | 62,39,894 |
4. The assessee has maintained the TP documentation as prescribed under the Section 92D of the Income Tax Act, 1961 (‘the Act’) and considered Transactional Net Margin Method as the "most appropriate method"
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