2022 (2) TMI 810

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.... For the Respondents : Lakshmi Narayanan , Sr. DR ORDER Per Yogesh Kumar Us , JM This appeal is filed by the Revenue and Cross Objection filed by the assessee against the order dated 23/07/2019 passed by CIT(A)-44, New Delhi for Assessment Year 2008-09. 2. The Department aggrieved by the order impugned has raised two separate grounds for not including the comparables by the A.O. i.e.....

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....es raised in the grounds of Appeal, the Arm Length Price charges would change to 37.5% to 41%, which is still within the tolerance margin of +/- 5% of the TP guidelines. 6. We, by taking note of the concerns expressed by the ld. CIT, DR and make it clear that as a result of the dismissal of the Revenue's appeal on the ground of low tax effect, the said order would not act as a precedent whe....