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13. The reliance was placed on the following case laws:

Ø ITO vs. Accurum India (P) Ltd. 128 TTJ 249 (Chen) Ø M. L. Outsourcing Pvt. Ltd. Vs. ITO (ITA No. 1204/Del/2011)

14. The ld. CIT(A) also reproduced the submissions of the assessee on the issues raised by the AO in his remand report at pages no. 18 to 21 which read as under:

"5.1 In paragraph 6 of the remand report, the Assessing Officer has contended that the appellant is ITA Nos. 4277 & 5744/Del/2012 IMSI India Pvt. Ltd.