2013 (4) TMI 267

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....against the order of the Assessing Officer dated 31.10.2011 passed u/s. 143(3) /144C of the I.T. Act pertaining to assessment year 2007-08. 2. The grounds raised read as under:- "1. The Ld. Disputes Resolution Panel and the Ld. ACIT (Ld. Assessing Officer) (following the directions of the DRP), erred on facts and in law, in enhancing the income of the appellant by Rs. 9,589,796/-, on account of t....

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....med, assets employed and risks assumed. 2.4 resorting to arbitrary rejection of low profit / loss making companies based on erroneous and inconsistent reasons; That the above grounds of appeal are without prejudice to each other. That the appellant craves to add, alter, amend or withdraw any ground of appeal either before or at the time of hearing of this appeal. 3. In this case assessee was i....

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....'s length price (ALP as per TP Study No. of comparables 7 Comparables' mean OP/TC 4.93% Appellant's OP/TC 20.80% Conclusion At arm's length 3.1 However, the TPO rejected the analysis as carried out by the assessee in his transfer pricing documentation. Assessee's submissions in this regard was that TPO retained an abnormally high profit making company namely Oil Field Instrumentation (India) Ltd. ....

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....s in light of the material produced and precedent relied upon. At the threshold, in this case the ld. Counsel of the assessee sought permission to file additional evidence in support of the grounds of the said appeal. The additional evidences sought to be admitted were with regard to the following i) Annexure-A Annual Repot of Oil Field Instrumentation (India) Limited for Financial year 2006-07. ....