2017 (2) TMI 346

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....ia, Sr. Standing Counsel with Sh. Puneet Rai, Jr. Standing Counsel, For the Respondent : Sh. Pranjal Srivastava, Advocate, O R D E R The revenue urges that the Income Tax Appellate Tribunal's (ITAT) decision, setting aside the assessments made by the Transfer Pricing Officer (TPO)/Assessing Officer (AO) after the search and seizure proceedings, culminating in a proceeding under Section 15....

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....sis of findings in Arms' Length Price (ALP) determination. The Disputes Resolution Panel (DRP) - upon the assessee's appeal reduced the rate of interest. The ITAT upon the assessee's further appeal quashed the assessment principally on the ground that in the absence of seizure of any incriminating material, the rule enunciated in CIT v. Kabul Chawla 2016 (380) ITR 573 (Del) was applicable invalida....