Ariba Technologies India (P.) Ltd. v. Dy. CIT (2025) 212 ITD 17 / 126 ITR 272 (Bang.)(Trib.)

S. 144C: Reference to dispute resolution panel-Transfer Pricing-Dispute Resolution Panel-Rectified directions-Assessing Officer bound to give effect-Transfer pricing adjustment deleted. [S. 92CA, 143(3), 144C(5), 144C(13)]

The Dispute Resolution Panel initially granted partial relief in respect of transfer pricing adjustments relating to software development and IT-enabled services. Subsequently, on the assessee’s rectification application, the Panel rectified its directions and the Transfer Pricing Officer passed a consequential order reducing the transfer pricing adjustment to nil. The Tribunal held that although the final assessment order had been passed before the rectified directions, the Assessing Officer was duty-bound to give effect to the revised directions of the Dispute Resolution Panel and the consequential order of the Transfer Pricing Officer. The Assessing Officer was directed to delete the entire transfer pricing adjustment. (AY. 2020-21).

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