TaxTMI 
TaxTMI 
2017 (7) TMI 812
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....the respondent ORDER P. C. 1. This appeal pertains to Assessment Year 2002-03. 2. The appellant assails the order passed by the Tribunal to the extent it confirmed the order of the Commissioner with regard to deletion of an amount of Rs. 74,79,266/. 3. Mr. Malhotra, the learned Counsel for the appellant strenuously contends that the appellant is engaged in the business of merchant banking, st....
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....in Method (TNMM) as was suggested by the assessee was not an appropriate method and CUP method, which is accepted by the TPO and the AO, is correct one. However, committed an error making T.P. adjustment. The reasoning given by the Assessing Officer is plausible one and based on reasons. There are two primary types of settlement mechanism i.e. Delivery Verses Payment (DVP) and Direct Custodian Set....
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....fficer considered the average brokerage rates charged for uncontrolled transaction as 0.56% in DVP trades and calculated the average brokerage rate. The Arms Length Price along with price was calculated based on the aforesaid rates. No error was committed by the TPO inter alia the Assessing Officer. There was no reason for the CIT(A) and Tribunal to interfere. 5. Mr. Pardiwala, the learned Senior....
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....NMM being appropriate method, has been negatived. 6. We have considered the submissions canvassed by the learned Counsel for the respective parties. The present appeal can only be entertained on substantial question of law. The CIT(A) and the Tribunal have concurrently accepted the case that there are difference in functions performed so also the risk undertaken by the assessee with respect to th....