2021 (9) TMI 1545

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..... For the Respondent : Shri Balakrishna (CIT-D.R.). ORDER PER SHRI S.S. GODARA, J.M. : This assessee's appeal for Asst. Year 2014-15 arises against the DCIT, Circle 3(1), Hyderabad's assessment dt. 30.10.2018 framed in furtherance to the Dispute Resolution Panel (DRP)-I, Bangaluru's direction dt. 5.9.2018 in F. No. 24/DRP-1/BNG/2081-19 in proceedings u/s. 143(3) r.w.s. 144C(13) of the ....

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....nally comparable, referring to the annual report of this company. We note that the assessee has not controverted the factual findings of the TPO. Therefore we upheld the selection of this comparable. 3.1.2 Cera Sanitary Ware Limited; and > Functionally not comparable. > Segments financials not available. > Engaged in R & D activities. 3.1.2.1 Having con....

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....afresh adjudication on merits after considering all the detailed evidence filed; as per law within three effective opportunities of hearing. 6. No other ground has been pressed before us at this stage since we are restoring the issue of selection of comparables in assessee's ground No.3(a) back to the DRP. All other substantive grounds are therefore rejected a consequential in nature at thi....

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....tained in good faith and with due diligence, despite satisfying the conditions prescribed under section 92C(3) of the Act; 3. b. rejecting the use of multiple year data and applying only single year data for comparability analysis; c. rejecting certain filters adopted in the transfer pricing study; and d. application of certain filters which are not relevant to the Assessee. O....