This is an appeal by the assessee being aggrieved by the Assessment Order dated 26.03.2021 pursuant to the directions dated 17.11.2020 of the Dispute Resolution Panel -I, New Delhi (for short hereinafter called “Ld. DRP”) for the assessment year 2016-17.
Brief facts of the case are that the assessee is a company and was 2 engaged in the business of consulting in the field of an environmental, health and safety, social land and natural resources management. For the assessment year 2016-17, they have filed a return of income on 30/11/2016 declaring an income of Rs.10,02,95,050/-. Noting that the assessee company made international transactions with the Associated Enterprises (“AEs”), the determination of arm’s-length price was referred to the Ld. Transfer Pricing Officer (“Ld. TPO”). By order dated 28/10/2019, Ld. TPO suggested to enhance the income of the assessee by Rs.2,10,22,69/-on account of interest on receivables from the AEs. After hearing the assessee, learned Assessing Officer passed the draft assessment order on 21/12/2019 under section 144C of the Income Tax Act, 1961 (for short “the Act”)
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