2011 (2) TMI 1574

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.... D. R. ORDER PER K. D. RANJAN, AM : This appeal is filed by the assessee and pertains to the assessment year 2006-07. 2. The grounds of appeal raised by the assessee are reproduced as under :- "1. The learned Assessing Officer and the Hon'ble Dispute Resolution Panel has erred both on facts and in law in confirming the unjust and illegal order of the Transfer Pricing Officer and makin....

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....of Transfer Pricing Officer's order determining the Arm's length price of international transactions. The second objection related to TPO in rejecting the comparables M/s. Nipuna Services Ltde., M/s. NIIT Smart Serva Ltd. and M/s. Godrej Upstream Ltd. The first objection was rejected by DRP on the ground that the assessee had not established that the data of the two preceding financial years have ....

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....all positively deal with the objections filed by the petitioner along with supporting evidence furnished by him to rebut the basis adopted by Transfer Pricing Officer to arrive at Arm's length price and thereafter only pass a speaking order. In the case before us the assessee has taken two objections. The DRP has not decided the objections raised by the assessee against the order of Transfer Prici....