Quotient Technology India Private Limited vs. Income Tax Officer

Parties Involved

Facts Summary

Quotient Technology India Private Limited, a wholly owned subsidiary of Quotient Technology Inc., provides software development services to its parent company. The assessee filed its return of income for the Assessment Year 2022-23, declaring total income of ₹48,091,490. The return was selected for scrutiny, and statutory notices were issued. The assessee reported international transactions, including software development services, and benchmarked these transactions using the transactional net margin method. The Assessing Officer referred the matter to the Transfer Pricing Officer for determination of the arm’s length price. The Transfer Pricing Officer conducted a comparability analysis and proposed an adjustment under section 92CA of the Income-tax Act, 1961. The assessee filed objections before the Dispute Resolution Panel, which issued its directions. The final assessment order was passed on 18 November 2025, assessing the assessee’s total income at ₹110,547,427, which is the subject of the present appeal.…

Legal Issues

• 1. Whether the order of the Assessing Officer, Transfer Pricing Officer, and Dispute Resolution Panel is prejudicial to the interest of the Appellant and is liable to be quashed.
• 2. Whether the learned Assessing Officer, Transfer Pricing Officer, and the Hon'ble Dispute Resolution Panel are justified in adjusting the Transfer Price by Rs. 6,24,55,937/- with respect to the international transactions undertaken by the Appellant.
• 3. Whether the assessment order under section 143(3) read with section 144C (13) is barred by limitation.
• 4. Whether the Dispute Resolution Panel is justified in upholding the action of the Transfer Pricing Officer/Assessing Officer in disregarding the Assessee's PLI computation and incorrectly recomputing the PLI by excluding rates and taxes amounting to Rs. 2,06,290 as non-operating in nature.
• 5. Whether the Assessing Officer erred in law and on facts in not giving effect to the binding directions issued by the Hon'ble Dispute Resolution Panel under section 144C (5) of the Income-tax Act, 1961.
• 6. Whether the Dispute Resolution Panel is justified in upholding the action of the Transfer Pricing Officer/Assessing Officer in conducting a fresh comparability analysis by introducing various filters for the purpose of determining the Arm's Length Price of the international transaction.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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