2020 (8) TMI 834

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....14-15. 2. The learned Authorized Representative submitted that there is a mistake apparent from the record in the order of Hon'ble Tribunal in respect of Ground of appeal No.3, where the assessee sought inclusion of 7 companies in the list of comparable for ITES segment. Whereas the Hon'ble Tribunal has rejected the comparable M/s. I2T2 India Limited for inclusion in Para 7(iv) on page 23 of the order as the income from export services is higher and is read as under : " 7(iv) I2T2 India Limited : This comparable was sought to be included by the assessee but was rejected by the TPO and RPT data are not available in the Annual Report. The DRP has observed that the company does not specify the filters adopted by the TPO and....

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....der that the Ground Nos.4C & 4D pertain to foreign exchange gain and Working Capital Adjustment and remanded to the file of TPO, which is read as under: " 10. Further, the learned Authorized Representative argued on Ground of Appeal No.4C and 4D in respect of Revenue not considering the foreign exchange gain and Working Capital Adjustment. Whereas the TP Adjustment was made to non-AE transactions and foreign exchange gain in ITES has to be considered. Considering these facts, we restore this disputed issue to the file of the TPO to consider the assessee's submissions and facts envisaged for determination of ALP. Accordingly, Ground of appeal of the assessee is allowed for statistical purposes." 6. The contentions of the LdAr tha....