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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
MADHUMITA ROY, Judicial Member, MANISH AGARWAL, Accountant Member
Kronos Solutions India Private Limited – Appellant
Versus
Dy. CIT, Circle-13(1) – Respondent
| Table of Content |
|---|
| 1. factual background of tp adjustments and proceedings (Para 2 , 3 , 6) |
| 2. exclusion of functionally dissimilar comparables in tnmm (Para 4 , 5 , 7 , 8 , 9 , 10 , 11 , 12 , 13 , 14) |
| 3. section 144c(13) one-month limitation mandatory (Para 15 , 16 , 17 , 18 , 19 , 20 , 21 , 22 , 23 , 24 , 25) |
| 4. appeal allowed; assessment order quashed (Para 26) |
ORDER
PER MANISH AGARWAL, AM:
This appeal is filed by the Assessee against the final assessment order dated 17.05.2022 passed u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (‘the Act’ for short) by the DCIT, Central Circle-13(1), New Delhi for the Assessment Year 2018-19.
2. Brief facts of the case are that the assessee company was incorporated in December, 2006 as a subsidiary of Kronos Solutions Inc. and engaged in the business of providing software services/solutions and back office support services to its Associated Enterprises (“AEs”). The assess is 100% export-oriented unit and is on offshore development center for Kronos US. The return of income was filed on 30.11.2018 declaring total income at Rs.47,16,32,260/-. Since, the assessee is having international transactions with its AEs, therefore, a reference was made u
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