AON CONSULTING PVT LTD vs PRINCIPAL COMMISSIONER OF INCOME TAX -1 & ORS.

IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 06.02.2025 ITA 244/2024 AON CONSULTING PVT. LTD. (SUCCESSOR ENTITY OF AON SERVICES (I) PVT. LTD. .....Appellant Versus PRINCIPAL COMMISSIONER OF INCOME TAX – 1 AND ORS. ....Respondents Advocates who appeared in this case: For the Appellant: Mr Deepak Chopra, Mr Harpreet Singh and Mr Priyam Bhatnagar, Advocates. For the Respondents: Mr Indruj Singh Rai, senior standing counsel with Mr Sanjeev Menon, Mr Rahul Singh and Mr Anmol Jagga, Advocates. CORAM HON’BLE MR JUSTICE VIBHU BAKHRU HON’BLE MS JUSTICE SWARANA KANTA SHARMA JUDGMENT VIBHU BAKHRU, J. 1. The appellant has filed the present appeal under Section 260A of the Income Tax Act, 1961 (hereafter the Act) impugning an order dated 20.12.2023 (hereafter the impugned order) passed by the learned Income Tax Appellate Tribunal (hereafter the ITAT) in ITA 09. 2. Hewitt Associates (India) Private Limited (since merged with the appellant) had filed the said appeal (ITA No.5418/Del/2012) assailing the transfer pricing adjustment (hereafter TP adjustment). The said TP adjustment was in two parts. One that related to the international transactions between Hewitt Associates (Ind