2016 (11) TMI 1732

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....oned herein are without prejudice to one another. General grounds 1.That the order of the learned Deputy Commissioner of Income Tax, Large Tax Payers Unit, Bangalore ('Assessing Officer' or 'AO') to the extent prejudicial to the Appellant, is bad in law and liable to be quashed. 2.That the Appellant craves leave to add to and/or to alter, amend, rescind, modify the grounds herein above or produce further documents before or at the time of hearing of this Appeal. Transfer Pricing Related 3.That the learned DRP erred in not appreciating the fact that the Appellant had prepared the TP documentation bona fide and in good faith in compliance with the Act and Income tax Rules, 1962 (&#3....

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....ng the TP documentation for comparable companies while determining arm's length price. (e) That the learned DRP erred in including companies in the comparability analysis which are different from the Appellant in functions, asset base and risk profile. (f) That the learned DRP erred in rejecting companies similar to the Appellant in functions, asset base and risk profile while performing comparability analysis. 5.That the learned DRP erred in arbitrarily adopting and imposing filters for arriving at the 9 comparable companies in the manufacturing segment. 6. That the learned DRP erred in making an adjustment to the appellant's entire sales, which included even third party sales and thereby going again....

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....ility on which interest is to be computed under section 234B. 11. The ld. AO erred in not considering the extension in due for payment of the fourth instalment of advance tax and consequently, computing higher interest under section 234C". 3. It is submitted by the ld.AR of the assessee that ground no.1,2,3,4c,4d and 7 are general and ground no.4b is not pressed and ground no.11 is consequential. Accordingly, ground no.4b is rejected as not pressed and it is held that no separate adjudication is called for regarding general and consequential grounds noted above. 4. Regarding remaining ground no.4a,4e,4f and 5 to 7 in respect of TP issues and ground no.8 & 9 in respect of Corporate Tax issues, it is submitted by the ld. AR of ....