TaxTMI 
TaxTMI 
2025 (4) TMI 2109
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.... of ITA No. 5543/Del/2018], ITA No. 3/DDN/2024 - -<br>Income Tax<br>SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI M. BALAGANESH, ACCOUNTANT MEMBER For the Assessee : Sh. Salil Kapoor, Adv., Sh. Anil Chachra, Adv., Sh. Utkarsa Gupta, Adv., Ms. Ananya Kapoor, Adv., Sh. Tarun Chanana, Adv., Sh. Shivam Yadav, Adv. For the Department : Sh. Amar Pal Singh, Sr. DR ORDER PER SATBEER SING....
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....rences ignoring the findings of the Ld. TPO. 2. Whether the Ld. CIT(A) was justified in rejecting the comparable companies having relatively higher margins. 3. Whether the Ld. CIT(A) was justified in rejecting M/s Crompton Greaves Ltd. As a comparable on the basis of existence of an event of amalgamation which cannot be verified, ignoring the findings of this office. 4. ....
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.... 3. It is at this stage that the learned counsel representing assessee's status at the bar that there arises the first and foremost issue of inclusion of M/s. Crompton Greaves Ltd. as a comparable whilst determining the arm's length price "ALP" of the respondent/taxpayer's international transactions with its overseas associates enterprises involving manufacturing segment. We are taken to page 57, ....
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....nal transactions and leave it upon open for the learned Transfer Pricing Officer (TPO) to finalize his consequential computation in very terms, as per law. All other grounds raised at the Revenue's behest in its instant appeal are accepted for statistical purposes in very terms. Ordered accordingly. This Revenue's appeal ITA Nos. 5543/Del/2018 is partly allowed for statistical purposes. 5. The ....