M/s. ADP Private Limited vs. Dy. Commissioner of Income Tax

Parties Involved

Facts Summary

The assessee company M/s. ADP Private Limited, engaged in providing Computer Software Development Services and Information Technology Enabled Services, filed its Return of Income for the Assessment Year 2017-18. The case was selected for scrutiny, and notices under section 143(2) and 142(1) were issued. The assessee submitted the required information, and the assessment was completed. The assessee preferred objections before the Learned Dispute Resolution Panel and further appealed to the Tribunal, raising 17 grounds of appeal. However, the assessee withdrew most of the grounds except Ground Nos. 4 and 13 due to a pending Bilateral Advance Price Agreement with the CBDT.…

Legal Issues

• 1. Interest on receivables to be benchmarked using LIBOR rate only.
• 2. Credit of tax for assets and liabilities taken over from an amalgamated company.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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