Deutsche Networks Services Pvt. Ltd. v/s Dy. Commissioner of Income Tax

Parties Involved

Facts Summary

The present appeal has been filed by the assessee, Deutsche Networks Services Pvt. Ltd., challenging the order dated 27/01/2012 passed by the Commissioner of Income Tax (Appeals) for the assessment year 2007–08. The assessee argued that the transfer pricing adjustment should be restricted to international transactions with non-resident associated enterprises. The Departmental Representative contended that the issue should be restored to the file of the Transfer Pricing Officer for necessary verification as the additional ground was not raised before the Transfer Pricing Officer or the Commissioner of Income Tax (Appeals). The Tribunal considered the submissions and material available on record.…

Legal Issues

• 1. Whether the transfer pricing adjustment should be restricted to the international transactions undertaken by the assessee with its associated enterprises.

Judgment Outcome

Decided in favour of Assessee.

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