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2019 (9) TMI 1679

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.... JM Aggrieved by the order dated 24/11/2016 passed under section 143(3) read with section 144C (13) of the Income Tax Act, 1961 (for short "the Act"), pursuant to the directions dated 30/9/2016 issued by the Ld. Dispute Resolution Panel (DRP)-I, New Delhi (Ld. DRP), M/s Greaves travel India private limited ("the assessee") filed this appeal mainly contesting the rejection of the Cost Plus Method....

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....t specified requests of its customers. In order to support its store operations, the assessee bought a small aircraft.But due to regulatory requirements by Civil Aviation Authority and in the absence of the Non-Scheduled Operators Permit licence (NSOP) the assessee was unable to operate the aircraft and therefore, the assessee had inducted the aircraft under the NSOP license of Air Works Engineeri....

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.... by the assessee to the AE, and suggested an upward adjustment to the tune of Rs. 3,01,99,649/-. 4. Assessee filed objections before the Ld. DRP challenging 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 ....

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....d in respect of the assessment years 2011-12 and 2012-13. He also submitted that when the matter for the assessment year 2011-12 travelled to the Tribunal, a coordinate Bench of this Tribunal in ITA No. 6722/Del/2015 by order dated 24/10/2018 followed the rule of consistency and accepted the CPM as the most appropriate method. He prayed that since the business model of the assessee remained the sa....