2019 (9) TMI 1679

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...."the assessee") filed this appeal mainly contesting the rejection of the Cost Plus Method (CPM) adopted by the assessee as the Most Appropriate Method for determination of the Arm's Length Price (ALP) and applying TNMM as the Most Appropriate Method with OP/TC as PLI. 2. Brief facts of the case are that the assessee is a private limited company engaged in the business of providing for operator and travel agents services and it provides comprehensive travel and tourism solutions for individuals and group leisure travels. The core business of the assessee has been the sale of packages for laser travel where two or more components of travel, such as flights, hotels, transportations, transfer and ground handling services are bundled together....

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....ng the action taken by the Ld. TPO. Ld. DRP by way of impugned order considered the suitability of oneKerala Travel Interserve Ltd to be included in the final list of comparables and directed the Ld. TPO to provide necessary material in respect of that entity to the assessee and to recompute the Arm's Length Price (ALP). 5. Aggrieved by the same, assessee filed this appeal mainly contesting the adoption of TNMM as the most appropriate method instead of CPM adopted by the assessee, and in the alternative to consider their contention that Kerala Travel Interserve Ltd is not at all comparable entity with the assessee for several reasons canvassed by them. 6. At the outset, it is the submission of the Ld. AR that in respect of the earlier....