Income Tax Appellate Tribunal Indore M/S. Computer Sciences Corporation ... vs The Asst. Commissioner Of Income ... on 10 April, 2023 ITA Nos.179/Ind/2016, 292/Ind/2017, 319/Ind/2018 & SA No.46/Ind/2021 A.Ys. 201112, 201213 & 201314 Page 1 of 29 IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE MS. SUCHITRA KAMBLE, JUDICIAL MEMBER AND SHRI BHAGIRATH MAL BIYANI, ACCOUNTANT MEMBER (Conducted through Virtual Court) ITA No.179/Ind/2016 Assessment Year: 20112012 M/s. Computer Sciences Corporation vs. The Asstt. Commissioner of India Private Limited, Income Tax 2(1), 19A, Electronic Complex, Indore. Aatmaram Choudhary Marg, Near Readymade Complex, Pardeshipura, Indore 452 010. [PAN AABCC 5820 A] ITA No.292/Ind/2017 Assessment Year: 201213 M/s. Computer Sciences Corporation vs. The Asstt. Commissioner of India Private Limited, Income Tax, Circle 2(1), 7 th Floor, Block1B, DLF IT Park, Indore. Shivaji Garden, Moonlight Stop, Nandanbakkam PostRamapuram, Chennai, Tamilnadu 600 089. [PAN AABCC 5820 A] ITA No.319/Ind/2018 Assessment Year: 201314 M/s. Computer Sciences Corporation vs. The Dy. Commissioner of India Private Limited, Income Tax, Circle 2(1), 7 th Floor, Block1B, DLF IT Park, Indore. Shivaji Garden, Moonlight Stop, Nandanbakkam PostRamapuram, Chennai, Tamilnadu 600 089. [PAN AABCC 5820 A] S.A. No.46/Ind/2021 (Arising out of ITA No.179/Ind/2016) Assessment Year: 20112012 M/s. Computer Sciences Corporation vs. The Asstt. Commissioner of India Private Limited, Income Tax 2(1), 19A, Electronic Complex, Indore. Aatmaram Choudhary Marg, Near Readymade Complex, Pardeshipura, ITA Nos.179/Ind/2016, 292/Ind/2017, 319/Ind/2018 & SA No.46/Ind/2021 A.Ys. 201112, 201213 & 201314 Page 2 of 29 Indore 452 010. [PAN AABCC 5820 A] (Appellant) (Respondent) Assessee by : Shri Vishal Kalra, Advocate Revenue by : Shri P.K. Mishra, CIT DR Date of hearing : 08.02.2023 Date of pronouncement : 10.04.2023 ORDER PER SUCHITRA KAMBLE, JUDICIAL MEMBER : These three appeals, pertaining to the same assessee, are filed by the assessee against three different orders dated 05.02.2016 passed by the ACIT, Circle 2(1), Indore for the Assessment Year 201112, order dated 14.12.2016 passed by the CIT(A)III, Indore for the Assessment Year 201213 & order dated 15.01.2018 passed by the CIT(A)I, Indore for the Assessment Year 201314 respectively. The assessee has also filed Stay Application in ITA No.179/Ind/2016 against the order passed by the ACIT, Circle2(1), Indore for the Assessment Year 201112. 2. The grounds of appeal are as under: ITA No.179/Ind/2016 for A.Y,. 201112 "Based on the facts and circumstances of the case, the appellant respectfully submits that the learned Assessing Officer ('ld AO') erred in determining the total income of the appellant at Rs.383,49,26,920/ as against the returned income of Rs.156,44,35,848/ filed by the appellant. The grounds of the appellant against the action of the ld. AO are as follows : 1. on the facts and circumstances of the case and in law the assessment order passed by the ld AO under Section 143(3) read with Section 144C(13) of the Income Tax Act, 1961 ('he Act') dated February 5, 2016 is without jurisdiction and is bad in law. 2. on the facts and circumstances of the case and in law the directions issued by the Dispute Resolution Panel (DRP) dated December 22, 2015 is without jurisdiction and is bad in law. The directions passed by the DRP are in violation of section 144C(8) of the Act. 3. on the facts and circumstances of the case and in law the assessment order