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5. The appellant craves, leave or reserving the right to amend modify, alter, add or forego any ground(s) of appeal at any time before or during the hearing of this appeal."

2. Briefly stated facts of the case are that the assessee company was incorporated under the law of India and is engaged in the business of trading of Xerographic Equipments, Printers, Scanners, Faxes, Multi-functional Devises, High-end printing equipment etc. The assessee filed return of income on ITA Nos.1088/Del./2016 & 1053/Del./2016 24.11.2011, declaring total income of Rs.7,36,28,531/-, which was revised on 29.03.2013. However, the revised income remained the same at Rs.7,36,28,531/-. The return of income filed by the assessee was selected for scrutiny assessment and statutory notices were issued and complied with by the assessee. The Assessing Officer noticed various international transactions carried out by the assessee and referred the matter for determination of the Arms' Length Price of the transactions to the Transfer Pricing Officer (in short 'the TPO'). The learned TPO though did not make any adjustment to the amount of the international transactions reported by the assessee, however, proposed an adjustment on account of international transaction, namely, "Creation of Marketing Intangible in favour of the AE"