TMI Blog2016 (9) TMI 1575X X X X Extracts X X X X X X X X Extracts X X X X ..... or may not happen unlike the marketing and technical risks which have to be contemporaneously dealt with by the comparables. ITAT did not accept that the risk adjustment should be by 5% or at the difference of PLR of the RBI and the banks, and directed the TPO to consider all the contentions and decide the percentage of risk adjustments to be made in accordance with law. Respectfully following ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2011-12. 2. The Department has filed the following grounds of appeal: (1) The directions of the Dispute Resolution Panel are opposed to law and facts of the case. 2. The Hon ble DRP erred in granting 1% risk adjustment arbitrarily without appreciating the facts of the case and its comparables. 3. The appellant craves leave to add, alter, amend and/or delete any of the grounds mention ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o be contemporaneously dealt with by the compa5rbles. The ITAT did not accept that the risk adjustment should be by 5% or at the difference of PLR of the RBI and the banks, and directed the TPO to consider all the contentions and decide the percentage of risk adjustments to be made in accordance with law. Respectfully following the decision of the Hon ble ITAT Bangalore as above the TPO is directe ..... X X X X Extracts X X X X X X X X Extracts X X X X
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