Document Fragment View

Matching Fragments

Appellant, M/s. CPA Global Support Services India Pvt. Ltd. (hereinafter referred to as 'the taxpayer') by filing the present appeal sought to set aside the impugned order dated 13.01.2017 passed by the Assessing Officer (AO) in consonance with the orders passed by the ld. DRP/TPO under section 143 (3) read with section 144C of the Income-tax Act, 1961 (for short 'the Act') qua the assessment year 2012-13 on the grounds inter alia that :-

"1. That on the facts and in the circumstances of the case and in law, the Hon'ble Dispute Resolution Panel ("DRP")/ Learned Assessing Officer ("AO")/ Learned Transfer Pricing Officer ("TPO") erred in making addition to the returned income of the appellant by INR 13,30,04,676/- by re-computing the arm's length price ("ALP") of international transactions under section 92 of the Income-Tax Act, 1961 ("the Act").
11. That DRP/AO/TPO erred on the facts and in the circumstances of the case and in law by not giving benefit of MAT credit to the Appellant in computation of income.
12. That DRP/AO/TPO erred on the facts and in the circumstances of the case and in law, in initiating penalty proceedings under section 274 read with 271 of the Act."

3. Briefly stated the facts necessary for adjudication of the controversy at hand are : M/s. CPA Global Support Services India Pvt. Ltd., the taxpayer, incorporated in September 2003 is into rendering Information Technology Enabled Services (ITES) related to IP administration / renewal and data management services to its group companies including renewal support services, proof reading support, customer support services etc.. The taxpayer functions as a captive off-shore centre in India and supports its Associated Enterprises (AEs) in servicing customer contracts. During the year under assessment, the taxpayer entered into international transactions with is AEs :