IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “H” BENCH: NEW DELHI BEFORE PRAKASH CHAND YADAV, JUDICIAL MEMBER &

SHRI MANISH AGARWAL, ACCOUNTANT MEMBER [Assessment Year : 2014-15]

Convergys India Services Private vs DCIT, Limited, Industrial Plot N-243, Circle-4(2), Tower-A, 1st, 3rd, 4th, 5th and New Delhi.

Tower-B, Ground, 2nd 5th Floor, S.P. Infocity, Udyog Vihar, Dundahera, Gurgaon, Haryana, 122016 PAN-AABCC5056G APPELLANT RESPONDENT Appellant by Shri K.M.Gupta &

Ms. Shruti Kimta, AR Respondent by Shri S.K.Jadhav, CIT DR Date of Hearing 22.07.2025 Date of Pronouncement 25.07.2025 ORDER PER MANISH AGARWAL, AM :

The present appeal is filed by the assessee against order of Ld.CIT(A)-44, Delhi in Appeal No.CIT(A), Delhi-2/10401/2017-18 dated 07.03.2023 for AY 2014-15 passed u/s 250 of the of the Income Tax Act, 1961 [“the Act”].

2. Brief facts of the case are that the assessee is a company, declaring total income at INR 1,52,79,96,910/- in the return of income filed on 29.11.2014. Since the assessee has entered into international transactions therefore, the matter was referred to TPO for determination of the Arm’s Length Price (“ALP”) of such transactions. The TPO vide order dated NIL has p