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

Judgment text excerpt

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 Signature Not Verified Digitally Signed By:GANGA SINGH RAWAT ITA 244/2024 Page 1 of 18 Signing Date:11.02.2025 18:27:27 No.5418/Del/2012 captioned Hewitt Associates (India) Pvt. Ltd. v. DCIT Circle-10(1), New Delhi, for the assessment year (AY) 2008-09. 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 (India) Private Limited (hereafter the Assessee) and Associated Enterprises (AEs) in the US (hereafter US Transactions) and the TP adjustment in respect of international transactions other than US Transactions (hereafter Non- US Transactions). Whilst the TP adjustment relating to US Transactions was determined at ₹41,79,89,294/-, the TP adjustment in