2022 (12) TMI 1204

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....short 'the Ld. DRP') for assessment year 2015-16. The grounds raised by the assessee in its appeal are reproduced as under: "On the facts and in the circumstances of the case, the learned TPO / AO/DRP have 1. erred in determining the total taxable loss of the Appellant at Rs 3,17,85,420 as against a loss of Rs 4,62,41,878 as reported in the return of income filed by the Appellant. 2. erred in rejecting the Appellant's transfer pricing analysis without providing cogent basis and making a transfer pricing adjustment of INR 1,44,56,458 in respect of deemed international transaction of television content production fees received from the broadcasters. 3. erred in rejecting documentary evidence including a....

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....emed AEs and is part of the revenues from the deemed As as reflected in the Appellant's Form 3CEB. 8. The learned AO has grossly erred in initiating penalty proceedings under section 271(1Xc) of the Act." 2. Before us the assessee has not pressed the ground No. one, ground Nos. 6 to 8 and therefore same are dismissed as infructuous. 3. In respect of ground No. 2 to 5 of the appeal, Ld. counsel of the assessee filed a request on behalf of the assessee for admission of the additional evidence. It was submitted by the assessee that in the case issue in dispute is in respect of determination of the arm's length price of 'deemed international transactions' of television content production fees received from the broadcasters. I....