The proceedings emerged from a return of income (ROI) filed by Vi Ltd for the Assessment Year 2016-17. The ROI disclosed a loss of ₹47,50,07,95,276 under normal provisions of the Act and loss of ₹292,80,62,889 under Section 115JB of the Act.
Vi raised a claimed of refund of prepaid taxes amounting to ₹1,128.47 crore in TDSAT.
The assessment was selected for scrutiny and notice under Section 143(2) of IT Act was issued. Since transactions of Vi involved international and specified domestic transactions with its associated enterprises, a reference was made to the Transfer Pricing Officer (TPO). The TPO passed an order proposing an adjustment to the value of the international transactions of Vi Ltd.
The Assessing Officer (AO) then passed a draft order on December 29, 2019, against which Vi Ltd filed objections.
The final directions by the Dispute Resolution Panel (DRP) were uploaded on the IT Business Application (ITBA) portal on the same date and the same was informed to Vi through an email.
Source: Barandbench
