IN THE ITAT, DELHI BENCH
ANIL CHATURVEDI, A.M. & KULDIP SINGH, J.M.
Barco Electronic Systems (P) Ltd. v. Dy. CIT
ITA No. 1531/Del/2016
11 November, 2020
In favour of assessee.
Assessee by: Mukesh Gupta, C.A.
Revenue by: Manoj Kumar Chopra, Sr. Departmental Representative
Anil Chaturvedi, A.M.
This appeal filed by the assessee is directed against the Order, dated 25-1-2016 of the Commissioner (A)-42, New Delhi relating to assessment year 2011-12.
2. The relevant facts as culled from the material on records are as under :--
3. The assessee is a company stated to be engaged in the business of manufacturing of projectors and parts and trading in visual display systems, projects and software and design operations. Assessee filed its return of income for assessment year 2011-12 on 29-11-2011 declaring total income of Rs. 31,67,00,693. The case was selected for scrutiny and thereafter notice under section 143(2) of the Act was issued on 19-9-2012 and served on the assessee. During the course of assessment proceedings assessing officer noticed that during the year under consideration, assessee has entered into International Transactions with 'Associated Enterprises' (AE) within the meaning of section 92B of the Act. He accordingly referred the matter to Transfer Pricing Officer for determining the Arm's Length Price' (ALP) under section 92CA(1) of the Act. The Transfer Pricing Officer vide Order, dated 15-1-2015 passed under section 92CA(3) of the Act proposed an adjustment of Rs. 39,55,013 on account of difference in arm's length price of the international transactions entered by the assessee with associated enterprises.