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2016 (9) TMI 1652 - HC - Income Tax
Condonation of delay - appeal is hopelessly time barred – by 670 days - HELD THAT:- The explanation given and heard cannot be termed as constituting “sufficient cause” requiring condonation of delay.
TP Addition - In addition to the delay, the revenue had appealed against an earlier order in respect of a similar direction by the ITAT [2015 (5) TMI 436 - DELHI HIGH COURT]. The court had upheld the decision even while requiring the TPO to take into consideration rule 10(B) of the Income Tax Rules while carrying out the ACP exercise.
The court had in the assessee’s appeal [2016 (7) TMI 1055 - DELHI HIGH COURT] also held in addition that an appropriate method would be TNMM - TPO is hereby directed to follow the directions of this court for AY 2009-2010 contained in both the appeals of the assessee and the revenue as well.
Appeal is disposed of.