2021 (7) TMI 582

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....ssee, while deciding the grounds of appeal in relation of ITeS segment, the Tribunal has directed the Assessing Officer to consider only the margin of international transaction of the assessee with its AEs and further directed that if the margin of the assessee was 37.54% and after giving the negative working capital adjustment of (-)8.64%, the margin of the assessee would fall within (+-) of the margins of the comparables, then the international transactions of the assessee should be considered at to be at ALP and no adjustment would be required. It is further submitted that thereafter, the Tribunal has held that it was not going into the acceptability or otherwise of the functional dissimilarities of the comparables challenged by the asse....

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....he learned Counsel for the assessee submitted that the assessee is not pressing this point for rectification. Therefore, on this issue we do not find any mistake which needs rectification. ii) The second point raised by the assessee in this M.A is in relation to the additions made of interest on advances. It is the case of the assessee that the Tribunal has not considered that these advances were given for the purpose of equity investment and that in the subsequent years, the investment was converted into equity and that the shares were allotted to the assessee company. It is submitted that the Tribunal has not considered its own decision in the assessee's own case in ITA No.267/Hyd/2014. 4. As regards this issue of interest on advances f....