INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
SHEELA FOAMS LTD GHAZIABAD – Appellant
Versus
ACIT CENTRAL CIRCLE-6 NEW DELHI – Respondent
ORDER
PER O.P. KANT, A.M.:
This appeal by the assessee is directed against final assessment order dated 29/11/2018 passed by the Ld. Assistant Commissioner of Income Tax, Central Circle - 06, New Delhi [hereinafter referred to as ‘the Assessing Officer’] for assessment year 2014-15 pursuant to the direction dated 28/09/2018 of Ld. Dispute Resolution Panel (DRP). The grounds of appeal raised by the assessee are reproduced as under:
1. That the Assessing officer erred on facts and in law in completing assessment under section 144C read with section 143(3) of the Income-tax Act, 1961 (’the Act’) at an income of Rs.26,54,56,338/- as against the income of Rs.20,97,70,100/- returned by the appellant.
2. That the Assessing officer erred on facts and in law in making an adjustment of Rs.5,56,86,238/- to the income of the appellant by doubting arm’s length price (‘ALP’) of certain specified domestic transactions undertaken during the relevant previous year.
2.1 That the Assessing officer/Dispute Resolution Panel (‘DRP’) erred on facts and in law in computing the adjustment to total income on ad hoc basis, by comparing profitability of the eligible unit with that of the other companies comparable
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