2020 (10) TMI 1170

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.... PRASAD FOR THE PETITIONER : SRI E I SANMATHI, ADV FOR THE RESPONDENT : BY SRI T.SURYANARAYANA, ADV JUDGMENT Mr. E. I. Sanmathi, learned counsel for the revenue. Mr.T.Suryanarayana, learned counsel for the assessee. 2. This appeal under Section 260-A of the Income Tax Act, 1961 (hereinafter referred to as 'the Act', for short) has been preferred by the revenue. The subject m....

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....of different case for different assessee for different assessment year without making any specific FAR analysis vis a vis the assessee company in contrast to the facts that these companies satisfy all the qualitative and quantitative filters applied by the TPO? 3. Whether, on the facts and in the circumstances of the case, the Tribunal were right in law in directing the TPO to apply RPT f....