Held that for the immediately succeeding assessment year, i. e., assessment year 2013-14, the Assessing Officer accepted the assessee’s submissions with regard to enhanced addition on account of suppressed income, and made no addition to its returned income in the final assessment order. Therefore, the Assessing Officer was to take into account the reconciliation of revenue according to the invoices vis-a-vis the financial statement and take a decision after affording a reasonable opportunity of hearing to the assessee. (AY. 2012-13)
Vmware Software India P. Ltd. v. Dy. CIT (2022)98 ITR 219 (Bang) (Trib)
S. 92C : Transfer pricing-Arm’s length price-Reconciliation of revenue-Matter remanded.