TaxTMI 
TaxTMI 
2016 (1) TMI 1199
X X X X Extracts X X X X
X X X X Extracts X X X X
....lkar,for the Respondent. JUDGEMENT This Appeal under Section 260-A of the Income Tax Act, 1961 (the Act) takes exception to the order dated 23rd January, 2013 passed by the Income Tax Appellate Tribunal (the Tribunal). The Assessment Year involved is A. Y. 2008-2009. 2 The Appellant has urged the following questions of law, for our consideration:- (A): Whether on the facts and in the circum....
X X X X Extracts X X X X
X X X X Extracts X X X X
....s with its Associated Enterprises(AE) in U. S. A. This resulted in the Assessing Officer making a reference to the Transfer Pricing Officer(TPO) to ascertain the correct Arm Length Price(ALP) of the transactions. (b) The TPO enhanced the consideration in respect of its international transaction to arrive at the ALP on operating margin at 7.32%. The Assessing Officer passed final assessment order....
X X X X Extracts X X X X
X X X X Extracts X X X X
....the Respondent- Assessee with its A.E.. However, the aforesaid grievance of the Revenue is no longer res integra, as this Court has in CIT v/s M/s Tara Jewels Exports Pvt Ltd (Income Tax Appeal No.1814 of 2013) decided on 5th October, 2015 and CIT v/s Thyssen Krupp Industries India Pvt Ltd (Income Tax Appeal No.2201 of 2013) decided on 2nd December, 2015), has taken a view that the ALP adjustment ....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... by Mr. Ahuja was faced by him. A copy of the order dated 27th August, 2013 was handed over to us across the bar and it is taken on record and marked Exhibit-"X" for identification. Moreover, we may point out that this was not the issue which was urged by the Revenue before the Tribunal. Thus, cannot be raised before us. (f) It was lastly urged on behalf of the Revenue that the impugned order ha....