2019 (11) TMI 1644

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....skaran, J. The assessee has filed this appeal challenging the assessment order dated 15-10-2018 passed by the Assessing Officer (AO) for assessment year 2014-15 u/s 143(3) r.w.s. 144C(13) of the Act in pursuance of directions given by Ld Dispute Resolution Panel (DRP). 2. All the issues urged by the assessee relate to the Transfer pricing adjustment made by the AO. 3. The assessee is engaged in....

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....rejected the T P Study conducted by the assessee. The TPO selected seven comparable companies by applying various filters, whose average margin worked out to 10.17%. Accordingly he made Transfer Pricing adjustment of Rs. 5,98,07,371/-. The same was confirmed by Ld DRP. 4. The Ld A.R submitted that comparable companies selected by the Ld TPO are engaged in food processing, which is totally differe....

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....ds Pvt. Ltd. L) Unicorn Pickles Pvt. Ltd. 5. The Ld A.R submitted that the assessee has gathered annual reports of the above said companies. Accordingly, he submitted that the TPO may be directed to bench mark the international transactions by considering the above said companies as comparable companies. 6. The Ld A.R further submitted that the TPO did not consider Export incentives as part of....

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.... the submission of the assessee that the comparables selected by TPO are engaged in different activities, though they are engaged in food processing only. The Ld A.R submitted that the assessee has already gathered annual reports of companies dealing in the very same product, i.e., gherkins dealt with by the assessee. Accordingly we are of the view that the issue relating to bench marking of inter....