2026 (5) TMI 319

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....ar 2017-18. 2. The assessee has taken the following concise grounds of appeal. 1- That the DRP-1/Assessing Officer/National e-Assessment Center ["NeAC"] erred on fact and in law in determining the income of the appellant at Rs. 3,46,49,803/- as against the NIL income returned by the appellant pursuant to the order of the Dispute Resolution Panel-1. New Delhi. 2- The TPO/DRP-1/National e-Assessment Center erred on fact and in law in not considering the additional evidence filed by the appellant during the proceeding before DRP vide letter dated 16/08/2021. 3- The TPO/DRP-1/National e-Assessment Center erred on fact and in law in making transfer pricing adjustment amounting to Rs. 22,54,738/- on account of intern....

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....rise. 7- That the TPO/DRP-1/National e-Assessment Center erred on facts and in law in disregarding the benchmarking analysis undertaken by the appellant by rejecting the comparable companies selected by the appellant on the ground of persistence losses. 8- That the TPO/National e-Assessment Center erred on fact and in law in in selecting the comparables which are functionally different to the business of the Appellant and DRP-1 sustaining the benchmarking analysis undertaken by the TPO which contains the selection of comparables that are not functionally most comparable with the business operations of the appellant. 9- The DRP/National e-Assessment Center New Delhi erred in charging of interest under the provision....

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....egmental Accounts of Bloomsbury Publishing India Private Limited for A.Y 2018-19 20 Not Applicable 4 Ld. Authorized Representative for the appellant/assessee submitted that certain evidence filed before DRP which were not filed before ld. AO were not considered by DRP. Segmental account of publishing loss and trading profits are to be filed. The similar segmental account for A.Y 2020-21 were accepted the Hon'ble ITAT in ITA No. 812/DEL/2021 for A.Y 2016-17 vide order dated 22.01.2025 had sent the matter to ld. AO for afresh decision. 5 Ld. Departmental Representative submitted that, the assessment was completed on the basis information provided by the assessee. He had no objection to the additional evidence considering the natur....