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INCOME TAX APPELLATE TRIBUNAL (COCHIN BENCH)
Shri Inturi Rama Rao, ACM, Shri Rahul Chaudhary, J
Applexus Technologies Private Limited – Appellant
Versus
Deputy Commissioner of Income Tax – Respondent
| Table of Content |
|---|
| 1. challenge to final assessment based on transfer pricing adjustments. (Para 1 , 2 , 3) |
| 2. arguments presented regarding the inadequacies of the earlier assessments and documentation. (Para 4 , 5 , 6) |
| 3. court's observations on segment data and economic impact considerations. (Para 7 , 8 , 9) |
| 4. interpretation of pli calculations and segmental analyses under prevailing law. (Para 10 , 11) |
| 5. conclusively allows the assessment appeal partially and directs further consideration. (Para 12 , 13) |
ORDER
Per Rahul Chaudhary, Judicial Member:
1. The present appeal has been preferred by the Assessee challenging Final Assessment Order, dated 13/09/2024, passed by the Assessing Officer under Section 143 (3) read with Section 144C read with Section 144B of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’], as per the directions issued by Dispute Resolution Panel - 2, Bengaluru [for short ‘DRP’], on 12/08/2024 under (5) of the Act for the Assessment Year 2021-2022.
2. The Assessee has raised multiple grounds of appeal which can be grouped as under:
Ground No.1: Incorrect rejection of transfer pricing documentation prepared by the Assessee
Ground No.2: PLI to be calculat
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