IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “C”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND SHRI VINAY BHAMORE, JUDICIAL MEMBER Assessment year : 2020-21 Liquidhub Analytics Pvt. Ltd. NFAC, Delhi (now merged with Capgemini Technology Services India Ltd.)

Vs.

Plot No.14, Rajiv Gandhi Infotech Park, Hinjewadi Phase III, MIDC SEZ, Village Man, Pune – 411057 PAN: AAFCA5135Q (Appellant) (Respondent)

Assessee by : Shri Nikhil Pathak Department by : Smt Nilu Jaggi, CIT Date of hearing : 11-02-2025 Date of pronouncement : 25-03-2025

O R D E R

PER R. K. PANDA, VP :

This appeal filed by the assessee is directed against the order dated

26.07.2024 passed by the Assessing Officer u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to assessment year 2020-21.

2. Facts of the case, in brief, are that the assessee, Liquidhub Analytics Pvt. Ltd. is a company and has an undertaking located in Special Economic Zone (SEZ) at Gurugram where it is engaged in the business of software development and other related information technology support services to its customers. It filed its return of income on 12.02.2021 declaring total income of