COMMISSIONER OF INCOME Vs. SAIPEM INDIA PROJECTS LIMITED

JUDGEMENT

(1.) This appeal is against a judgment and order dated 25th November, 2016 passed by the Income Tax Appellate Tribunal "D" Bench, Chennai, partly allowing the appeal of the respondent assessee being I.T.A.No.401/Mds/2016, in relation to the assessment year 2011-12 against an order dated 21st December, 2015 of the Assessing Officer under Section 143(3) of the Income Tax Act, 1961, hereinafter referred to as "the said Act").

(2.) The respondent assessee, which provides engineering services, filed its return for the assessment year 2011-12 disclosing the income of Rs.3,31,83,584/- and Rs.6,37,96,564/- under Section 115JB of the said Act.

(3.) As the respondent assessee had entered into an international transaction with its Associated Enterprises exceeding a value of Rs.15.00 Crores, a reference was made to the Transfer Pricing Officer, hereinafter referred to as "the TPO".