9911796707
TMI Blog2018 (4) TMI 1739X X X X Extracts X X X X X X X X Extracts X X X X ..... ITAT reversed the AO s determination based upon a decision in the case of CIT vs. Genpact India [ 2011 (11) TMI 119 - DELHI HIGH COURT] . In these circumstances, we are of the opinion that no question of law arises on this aspect Quantum of the risk adjustment - Dispute Resolution Panel (DRP) had modified from the initial 1% determined by the Transfer Pricing Officer (TPO) - HELD THAT:- I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 875/2018 With ITA 414/2018 - - - Dated:- 11-4-2018 - Mr. S. Ravindra Bhat And Mr. A. K. Chawla, JJ. Mr. Asheesh Jain, Sr. Standing Counsel with Mr. Ajit Sharma, Jr. Standing Counsel for the Revenue. ORDER Admit. The Revenue urges three questions of law in ITA No.414/2018; the first is with respect to the deduction under Section 10A of the Income Ta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed by the Transfer Pricing Officer (TPO). The ITAT upheld the DRP s determination holding that the AO had to amend the draft assessment order after the DRP s adjustment. This Court is of the opinion that there is no infirmity in the order of the ITAT. The DRP s mechanism is an administrative and corrective process entitling the assessee to insist upon a second look in regard to the issues decid ..... X X X X Extracts X X X X X X X X Extracts X X X X
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