2025 (8) TMI 46

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...., CIT-DR ORDER PER PRAKASH CHAND YADAV, JM: The present appeal of the assessee is arising out from the order of Ld. Assessing Officer dated 25th September, 2024 having DIN No. ITBA/AST/S/143(3)/2024-25/1069101879(1) and relates to Assessment Year 2021-22. 2. The assessee has raised five grounds of appeal, out of which Ground No.3,4,5 are consequential and hence, does not require adjudication. ....

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....63,89,216/. The case of the assessee was selected for scrutiny. Thereafter, for determining the ALP of the supports services rendered by assessee to its AE, a reference was made by the Assessing Officer to the TPO. Accordingly, the TPO computed the ALP and sent the order to the Ld. AO. The Assessing Officer passed draft assessment order, against which the assessee filed its objections before the D....

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....a Company from the list of comparable. Perusal of the financials of Madhaya Pradesh Today Media Company would so that this company is engaged in business and selling of newspaper and not carrying on any business similar to the assessee. On the other hand, the nature of business conducted by the assessee altogether different, therefore, we conclude that this comparable is not functionally similar t....