2022 (1) TMI 1304

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....t appeal has been filed by the revenue against the order of ld. CIT(A)-44, New Delhi dated 28.02.2018. 2. Following grounds have been raised by the revenue: "1. Whether the order of ld. CIT(A) is perverse in accepting the internal TNMM of the assessee ignoring the fact that the assessee company has been changing its stand before the authorities and even offered adjustment under external TNMM du....

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....f three months. At this juncture we feel it is no more required. Hence, it is decided to dispose the appeal on the merits of the case. 4. In the case, the AO made addition on account of Transfer Pricing adjustment of Rs.1,67,85,136/- which culminated into contraption of returned loss of Rs.7,80,30,578/- to Rs.6,12,26,929/- The assessee has enclosed the export segment results, indicating that the ....