2014 (2) TMI 651

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....spondent : Shri Peeyush Jain ORDER Per Bench: These two appeals by the Revenue for the assessment years 2004-05 and 2005-06 and one Cross Objection by the assessee for the assessment year 2004-05 are directed against the common order passed by the CIT(A) on 27.6.2012. Since some of the issues raised in these appeals are common, we are therefore, proceeding to dispose them by this consolidated o....

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....mittedly similar to those of ground no. 7 for the assessment year 2003-04, which has not been allowed by us in our separate order. Following the view taken for the assessment year 2003-04, this ground is not allowed. 4. Ground No. 2 is against deletion of transfer pricing addition on account of Arms's Length Price amounting to Rs. 2,28,66,074/-. For this year also, the assessee adopted Profit Lev....

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.... the Revenue as ground no. 2 for the assessment year 2003-04. We have accepted the assessee's contention about the correctness of the ld. CIT(A)'s order on this issue in accordance with the tribunal order for the still earlier year. It is further noticed that the Hon'ble Supreme Court in Ajanta Pharma Ltd. Vs CIT (2010) 327 ITR 305 has held on this issue that : `Clause (iv) of the Explanation to s....

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....ue is partly allowed and the CO of the assessee is allowed for statistical purposes. Assessment Year 2005-06 7. First ground of the Revenue's appeal is against the deletion of disallowance of training expenses amounting to Rs. 5,31,500/-. It is noticed that similar issue was involved in the Revenue's appeal for the assessment year 2003-04 through ground no. 5. We have upheld the ld. CIT(A)'s vie....