M/s Xerox India Limited Vs. DCIT

Parties Involved

Facts Summary

The assessee company, Xerox India Limited, is the Indian subsidiary of Xerox US, based in Gurgaon, India. It primarily functions as a distributor of Xerox Technology Products imported from Xerox US and provides routine support services to its AEs. The company filed its return of income for A.Y. 2020-21 on 12.02.2021 declaring a total income of Rs. 25,18,36,530/-. The case was selected for scrutiny through CASS on issues such as foreign remittance to low tax jurisdiction countries, claim of large value refund, high-risk international transactions, and reduction in profit due to the application of income computation disclosure standards. Notice u/s 143(2) of the Act was issued on 29.06.2021 and the case was allocated for complete scrutiny in a faceless manner. The assessee company also filed Form 3CEB on 24.12.2020 showing an aggregate value of international transactions of Rs. 325,37,51,386/-. The case was referred to the Transfer Pricing Officer for determination of Arm's Length Price.…

Legal Issues

• 1. Whether the AO/DRP erred in not adjudicating upon the claim raised by the appellant vide letter dated 12th February 2021.
• 2. Whether the Dividend Distribution Tax (DDT) paid by the appellant is in excess of the applicable rates under relevant DTAA’s.

Judgment Outcome

Decided in favour of Revenue.

Precedents Relied Upon

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