2015 (4) TMI 1107

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....ard Mr. Pinto and perusing the order of the Tribunal, we find that the appeal deserves to be admitted as it raises substantial questions of law. It is admitted on the following three substantial questions of law : "(1) Whether on the facts and circumstances of the case and in law, the Hon'ble ITAT is justified in holding that the Transfer Pricing Officer ought to have confined himself....

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....y and not on pro rata basis ? (3) Whether on the facts and circumstances of the case and in law, the Hon'ble ITAT is justified in deleting the addition of Rs. 1,29,55,813/- holding that the adjustment is within +/- 5% as the ITAT has wrongly worked out adjustment on sales, whereas the TPO had benchmarked the purchase transactions and had worked out the adjustment on purchases. Therefo....