McCann Erickson India Pvt. Ltd. vs. DCIT, Circle 16 (1)
Case No: ITA No.3833/DEL/2024
Court: INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH ‘H’: NEW DELHI
Date: 3/19/2025
Parties Involved
appellantMcCann Erickson India Pvt. Ltd.
respondentDCIT, Circle 16 (1)
Facts Summary
The case involves McCann Erickson India Pvt. Ltd., which is engaged in providing advertising services. The company filed its return of income for the assessment year 2020-21, disclosing a total income of Rs.33,46,86,880/-. The case was selected for scrutiny due to various discrepancies and high-risk international transactions. The Assessing Officer referred the case to the Transfer Pricing Officer (TPO) who made an adjustment of INR 8,45,84,864 to the appellant's total income based on the provis…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the TPO and AO erred in making an adjustment of INR 8,45,84,864 to the Appellant's total income.
- 2. Whether the AO (Technical Unit) had the powers to make a reference u/s 92CA (1) of the Act.
3 more legal issues analysed in this judgement.
Precedents Relied Upon
2 precedents cited in this judgement.