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2021 (9) TMI 1545 - ITAT HYDERABADTP Adjustment - comparable selection - assessee restricted his pleadings only qua wrongful inclusion of two comparables M/s. HSIL Ltd and M/s. Cera Sanitary Ware Limited by the Transfer Pricing Officer (TPO) - HELD THAT:- DR fails to dispute that the DRP herein has nowhere taken into consideration the assessee's detailed objections quoting functional similarity, lack of the relevant segmental financials and engagement of the said twin entities in R & D activities, whilst declining the impugned objection in a cryptic manner. Faced with this situation, we deem it appropriate to restore the assessee's instant substantive grounds back to the DRP for its afresh adjudication on merits after considering all the detailed evidence filed; as per law within three effective opportunities of hearing. Assessee's appeal is partly accepted for statistical purposes.
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