MERCER CONSULTING (INDIA) PVT. LTD. Vs. DCIT

JUDGEMENT

(1.) THIS appeal by the assessee arises out of the order passed by the Assessing Officer (AO) on 07.01.2014 u/s. 144C(13) of the Income -tax Act, 1961 (hereinafter also called 'the Act') in relation to the Assessment year 2009 -10.

(2.) THE first issue agitated in this appeal is against the transfer pricing adjustment of Rs. 6,16,24,726/ - made by the AO on the same being proposed by the Transfer Pricing Officer (TPO) and as approved by the Dispute Resolution Panel (DRP).

(3.) THAT is how the TPO determined arm's length price (ALP) of this set of international transactions at a margin of 34.19% and proposed adjustment u/s. 92CA for a sum of Rs. 6,16,24,726/ -. The assessee was unsuccessful before the DRP who upheld the draft order passed by the AO on the strength of the order passed by the TPO. The assessee is aggrieved against this TP addition made by the AO in his final order.