The Deputy Commissioner of Income Tax, Circle – 4(1)(1), Bangalore. Vs. M/s. EYGBS (India) Pvt. Ltd.

Parties Involved

Facts Summary

The assessee, M/s. EYGBS (India) Pvt. Ltd., a subsidiary of EYGI B.V., Netherlands, is engaged in providing back office support services. The assessee filed a return of income and later a revised return claiming deductions under section 10AA of the Act. The case was selected for scrutiny, and the Assessing Officer issued notices under sections 143(2) and 142(1) of the Act. The Transfer Pricing Officer proposed a transfer pricing adjustment, which was later reduced by the assessee. The Assessing Officer passed a draft assessment order disallowing certain deductions and credits. The assessee appealed to the Commissioner of Income Tax (Appeals), who set aside the order of the Assessing Officer. The Revenue appealed to the Income Tax Appellate Tribunal, challenging the order of the Commissioner of Income Tax (Appeals).…

Legal Issues

• 1. Allowance of deduction under section 10AA of the Act on voluntary adjustment made to ALP.
• 2. Deletion of addition made by the AO under section 14A of the Act.
• 3. Deletion of foreign exchange loss by the Ld.CIT(A).
• 4. Exclusion of comparables by the Ld.CIT(A).

Judgment Outcome

Decided in favour of Revenue.

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