M/s TDK India Pvt. Ltd. (formerly known as EPCOS India Pvt. Ltd.) Vs. DCIT, Circle-11(1), Kolkata
Case No: I.T.A. No. 203/Kol/2021 & I.T.A. No. 282/Kol/2022
Court: Income Tax Appellate Tribunal, 'C' Bench, Kolkata
Date: 1/22/2025
Parties Involved
appellantM/s TDK India Pvt. Ltd. (formerly known as EPCOS India Pvt. Ltd.)
respondentDCIT, Circle-11(1), Kolkata
Facts Summary
The assessee, M/s TDK India Pvt. Ltd., filed its return of income declaring a total income of nil after adjusting income with brought forward losses. The case was selected for scrutiny, and statutory notices were issued. The assessee filed an audit report in Form 3CEB for international transactions. The case was referred to the Transfer Pricing Officer (TPO) for determination of transfer pricing adjustment in respect of intra-group services by associated enterprises. The TPO determined an adjust…
Decision in favour of
Assessee
Legal Issues
- 1. Confirmation of addition of Rs. 12,54,93,154/- by the DRP in respect of intra-group services.
- 2. Transfer pricing adjustment made in relation to sales margin by the TPO.
3 more legal issues analysed in this judgement.
Precedents Relied Upon
11 precedents cited in this judgement.