2019 (11) TMI 1644

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....eep Kumar, CIT (DR) ORDER B.R. Baskaran, 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 mad....

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....he comparable companies. Accordingly the TPO 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 engag....

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..... H) Green Pickles Pvt. Ltd. I) Ken Agritech Ltd. J) Koeleman India Pvt. Ltd. K) Neo Foods 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 abov....

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....essee to consider the companies, which are engaged in the similar line of business in the very same product, as comparable companies. It is 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 ver....