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2015 (7) TMI 370 - HC - Income TaxObjection in selection of comparable companies - Inclusion of comparable companies chosen by the TPO, which were functionally not comparable - Non-adjudication of certain grounds raised by appellant in the appeal memo - Question of limitation - Held that:- Non-adjudication of certain grounds raised by appellant in the appeal memo - As regards the third question, learned counsel for the appellant contended that the Tribunal had wrongly recorded that the assessee's counsel had confined the grievance on behalf of the assessee to the inclusion of four comparables in software service segment and that it had only been argued that the comparables mentioned therein had been wrongly included by the TPO. Learned counsel for the appellant has invited our attention to the written submissions filed before the Tribunal. This contention must at least, in the first instance, be raised by the appellant before the Tribunal. The appellant is at liberty to do so. In the event of the Tribunal not entertaining the application, the appellant is at liberty to adopt appropriate proceedings including in any appeal that may be filed against the main order. Other issues may be taken after final decision of the tribunal There would be no question of limitation, in such a case. The limitation would begin only after the final decision of the Tribunal.
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