2022 (9) TMI 1524

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....i S. S. Tomar, Adv.; & Shri Vishu Goel, C. A. For the Revenue : Shri M. Baranwal, Sr. D. R. ORDER PER C. N. PRASAD, J. M. : 1. Through this Misc. application the assessee prays for restoring/recalling the order of the Tribunal in ITA. No. 516/Del/2015 dated 20.03.2018 for the assessment year 2010-11 for the limited purpose of adjudicating ground No. 3.5 of grounds of appeal of the assessee vi....

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....ies for the assessment year 2010-11 and written arguments were placed at page 33 of the paper book. Therefore, the ld. Counsel for the assessee submits that the Tribunal in its order in ITA. No. 516/Del/2015 dated 20.03.2018 did not adjudicate ground No. 3.5 completely in the sense that one of the comparable companies, namely, Eclerx Services Limited which was disputed by the assessee was not adju....

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....ning the arm's length price ("ALP") of the Appellant's international transactions at Rs.l61,838,198/- as against Rs.141,550,138/- determined by the Appellant and recommending an addition of Rs.20,288,0601- on that account to the Appellant's income by : 3.1 modifying the comparability analysis conducted in the transfer pricing documentation of the Appellant on inappropriate and inade....

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....s of appeal the assessee specifically challenged the order of the Assessing Officer in selecting companies, which were not comparable to the assessee. The assessee made its submissions before the Tribunal for exclusion of Eclerx Services Limited, which is placed at page 33 of the paper book. However, the Tribunal while passing the order in ITA. No. 516/Del/2015 dated 20.03.2018 inadvertently omitt....