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2015 (7) TMI 157 - ITAT AHMEDABAD

2015 (7) TMI 157 - ITAT AHMEDABAD - TMI - Transfer pricing adjustment - Selection of comparable - Held that:- CIT(A) was not justified in giving any opinion about the correctness or otherwise of the TPOs order for Assessment Year 2005- 06, because that was not under appeal before him. However, be that as it may be, we have heard both the parties with regard to the method to be followed while comparing the raw-material component of the assessee as well as comparables. After considering the argum .....

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ies and therefore, is un-controlled transaction. In view of above, in the light of OECD guidelines, while working out ratio of raw-material should be worked out by comparing the raw-material vis--vis sales. In this view of the matter, we uphold the finding of the TPO for the year under appeal wherein he arrived at the conclusion that the assessee should be allowed the adjustment of 18.50% because of excess consumption of raw-material. However, in our opinion, while giving the adjustment, the as .....

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and restore the matter back to the file of the Assessing Officer.

Set off of part of losses against the income - Held that:- The appellant is entitled to set off of the business loss pertaining to AY 1997-98 in its case against its profit of AY 2004- 05 in view of provisions of section 79 of the IT Act. As regards remaining losses in the case of appellant, the same cannot be denied to be carried forward by the AO u/s.79 of the Act while completing the assessment for AY 2004-05. As sta .....

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Act while completing the assessments in the case of appellant for such subsequent assessment years. - Decided against revenue. - I.T.A.No.2210/Ahd/2012,I.T.A.No.2154/Ahd/2012 - Dated:- 26-6-2015 - Shri G.D. Agarwal and Shri kul bharat, JJ. For the Petiitoner : Shri S.N. Soparkar with Sachit Jolly, Adv. ,Madhavi Rathi, Nishant Periwal & Bandish Soparkar ARs For the Respondent: Shri T.P.Krishnakumar, CIT-DR with Shri B.Y. Chauhan, TPO ORDER PER BENCH : These two appeals by the Assessee and the .....

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)-IV, Baroda [hereinafter referred to as CIT(A) ] under section 250 of the Income-tax Act, 1961 ( the Act ) to the extent prejudicial to the Appellant, is perverse, erroneous on facts and bad in law. 2.1. That on the facts and circumstance of the case and in law, the CIT(A) exceeded its jurisdiction contemplated in Section 251 of the Act, by enhancing the income of the Appellant on account of denial of claim for bad debts written off through provision for bad debt account of ₹ 7,53,08,028. .....

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ile computing the raw material adjustments of the Appellant Company and the comparable companies in the manufacturing segment of the PCDTA division and consequently arriving at the revised operating margin of comparable companies. 3.3. Without prejudice to the above, the learned CIT(A) has erred in not appreciating the error made by the learned Transfer Pricing officer in computing the raw material adjustment and the consequent operating margin of the Appellant Company. 3.4. That the learned CIT .....

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recorded by the ld.CIT(A) in his order read as under: 10.1 The brief facts in the case of appellant are that after amalgamation / merger of above entities in to it as per orders of above Hon'ble Courts, a revised return of income along with audit report, tax audit report, statement of computation of income etc. were filed on 31- 03-2006. The AO on perusal of computation of income noticed that the appellant company had consolidated the figures of business income of itself as well as of the ab .....

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83/- and income from other sources was shown at ₹4,64,712/- totalling to ₹2,64,33,995/-. However, after setting of the carried forward losses and depreciation, the total income was shown at Nil in the revised return of income. As per Para-5 of the Audit report, vide Para l(b) it was observed by the AO that the financial statements were prepared and presented under the historical cost convention on the basis of accounting ............ Provisions of the Companies Act, 1956 to the exten .....

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cheme being made operational. 10.2 From the plain reading of the order of the Hon'ble High Court as well as the accounting practices and policies adopted by the Board of Directors subsequent to the merger/amalgamation, as per the A.O. there was no scope of any alignment in the accounting practices and policies including taxation matters in the books of accounts of the new entity i.e. the appellant. As per the AO the scheme of merger was approved with the appointed date which was 01-04-2003 a .....

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ate returns of income along with statutory audit report as well as tax audit report u/s 44AB of the Act were filed by all the companies before the respective AOs and details of which are mentioned by the AO on Page No.4 of assessment order. As per the AO had the scheme of arrangement/ amalgamation/merger not taken place, for the sake of argument, then all the above referred companies as separated and distinct entities would have been assessed to tax before their respective assessing officer. As .....

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y the appellant company are to have been submitted on simple consolidation basis because the previous year relevant to A.Y. 2004-05 was over on 31-03-2004 i.e. much prior to the order of Gujarat High Court. Thus as per the AO under the circumstances, the net result of disallowable, allowables, income from other sources shall be on consolidation basis and there was no scope whatsoever to make any amendment/ alteration, modification in the crystallized and closed and adjusted books of accounts of .....

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nt company i.e. GEII. As per the AO however, in fact, the picture was totally different and the same was showing gross violation /deviation from the so called principles claimed and adopted in the revised audit report. As per the AO such violation / deviation are as under: 10.2.1 As per the AO all the companies as listed above which were part of the scheme of arrangement in their respective original returns of income filed on the basis of their respective audit reports claimed / added disallowab .....

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r profit and loss account should have been naturally ₹62,63,45,413/-. As per the AO however on perusal of revised return of income such disallowables were considered at ₹51,25,39,846/-. Thus as per the AO the act of the appellant company of reduction in the amount of disallowables to the tune of ₹11,60,49,285/- was neither justified nor maintainable within the provisions of law. The AO was of the view that the figures shown as disallowables in the respective returns of the abov .....

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es' returns of income would have been assessed considering the disallowables offered by them without any alignment what so ever. In view of this the AO held that the appellant company re-casted the quantum of disallowables in the revised return of income with a view to reduce taxable income. Accordingly AO added an amount of ₹11,60,49,285/- to the total income of the appellant. 10.2.2 Likewise, the AO on perusal of this Annexure-B, further noticed that the total allowables considered b .....

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from the total income of the appellant in all fairness as there was no deviation or alignment in the accounting policies of the respective companies. Accordingly, the AO deducted this amount of ₹2,24,77,605/- from the total income of revised return of the appellant. 10.2.3 The AO on perusal of this Annexure-C noticed that the total income from other sources considered by respective companies in their returns of income were totaling to ₹28,84,598/-. As per the AO accordingly while com .....

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duced to the tune of ₹24,19,886/- (i.e. ₹28,84,598/- ₹4,64,712/-) and the same was added by him to the total income of the appellant. 10.3 In view of the above discrepancies with regard to disallowables and allowable of business income and income from other sources, the AO held that the revised return of income of the appellant was not showing the true state of affairs and accordingly he rejected the books of accounts of the appellant u/s 145(3) of the IT Act. 3.1. The AO furth .....

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s. 4. First ground of assessee s appeal is general in nature which require no independent adjudication. 5. Ground Nos.2.1 & 2.2 are inter-connected and, therefore, the same are decided together. The ld.counsel for the assessee submitted that the ld.CIT(A) travelled beyond the record and made enhancement on the matter that was neither considered by the AO nor was a subject matter of appeal. In support of this contention, the ld.counsel for the assessee placed reliance on the judgment of Hon b .....

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ent of Hon ble Karnataka High Court rendered in the case of Sterling Construction And Trading Company vs. Income-tax Officer, Central Circle-1, Bangalore, And Others reported at 1975-(099)-ITR-0236-Kar. He also placed reliance on the judgement of Delhi High Court rendered in the case of CIT vs. Union Tyres reported at 1999-(240)-ITR-0556-Del. and of CIT vs. Sardari Lal & Co. reported at 2001-(251)-ITR-0864-Del. [FB]. Further, he placed reliance on the judgement of Hon ble Gujart High Court r .....

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Rai Bahadur Hardutroy Motilal Chamaria (66 ITR 443) and CIT v Shapoorji Pallonji Mistry (44 ITR 891). The relevant extracts of the judgments are attached as Annexure 1. In the facts of the instant case, CIT(A) vide the notice dated June 22, 2012 issued under Section 251(2) of the Act sought details and evidences to demonstrate that the subject bad debts pertained to the business of the Appellant and was considered as income in prior years. Further, the Ld. CIT(A) also sought details and evidenc .....

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ompassed in the enhancement power of the AAC. Reliance in placed on the judgments of the Gujarat High Court in the case of Prabhudas Ramji v CIT (1966) (62ITRITR 621) and CIT v Jagdish Mills Ltd (1964) (51 ITR 266); Karnataka High court in the case of Sterling Construction And Trading Company v ITO (1975)(99 ITR 236). It is further contended that the power of enhancement by CIT(A) contemplated in Section 251 of the Act does not include the power to discover new source of income. This contention .....

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he appeal or proceedings before the lower authorities, with a view to enhance income of the Appellant. The Ld. CIT(A), to emphasise that the powers conferred in his office are not restricted has relied on the judgments of the Supreme Court in the cases of CIT v Nirvheram Daluram (1997) (224 ITR 610), Jute Corporation of India (1991) (187 ITR 688) and CIT v Kanpur Coal Syndicate (1964) (53 ITR 225). However, the reliance placed by the Ld. CIT(A) is misplaced viz a viz the contention raised by the .....

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judgment of Gujarat High Court in the case of Saheli Synthetics Pvt Ltd v CIT (302 ITR 126) to contend that an appellate authority can even process a new source of income which forms part of either the return of income or the order of assessment. However, this reliance is also misplaced as the said judgment deals with the right of the AO to tax new source of income while framing a de novo assessment on the direction of the CIT(A). Moreover, the judgment itself recognizes that "powers avail .....

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return of income thereby meaning that this source of income has been removed from the tax computation. Further, as stated earlier, the issue of bad debts had not been considered by the Ld. AO during the course of assessment. To buttress the contention of jurisdiction, the Ld. CIT(A) relied on the judgment of the Delhi HC in the case of Gurinder Mohan Singh Nindrajog v CIT (348 ITR 170). However the said reliance is also misplaced and distinguishable on facts. In the said case, the subject matte .....

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d. AO. Accordingly, it is submitted that the subject bad debts were not considered by the Ld. AO and enhancement by the Ld. CIT(A) on that account after roving enquires would tantamount to discovery of new source of income which is beyond the jurisdiction of his office. Indirect way of making additions beyond the limitations period Without prejudice to the above, it is contended that enhancement based on intimation by the Ld. AO after the expiry of time limits of reopening assessment would tanta .....

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quid prohibetur, prohibetur at omne per quod devenitur ad'illud" meaning that whatever is prohibited by law to be done, cannot legally be effected indirectly. Reliance placed on the judgment of Supreme Court in the case of U.P. Cooperative Federation vs. Singh Consultants, 1988 (1) SCC 174 and Sangramsinh Vs. Shantadevi, 2005 (11) SCC 314. Further reliance to substantiate this principles applicability in the context of Income-tax is placed on the following judgments: • Anupam Susil .....

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xt of Section 34 of the Income-tax Act, 1922. The relevant extract has been attached as Annexure 3. The Ld. CIT(A) to fortify its contention that enhancement may be made on the intimation of the AO has relied on the judgment of the P&H High Court in the case of Goel Die Cast Ltd v CIT (297 ITR 72). However, the Company submits that the said judgment is distinguishable as in the facts of that case, the enhancement, albeit on an intimation by the AO, was within the time limit of re-opening of .....

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ebit to the "Provision for bad debt account". This in itself would demonstrate that the subject debts have been written off from the ledger of the debtor. The judgment of CIT v Hotel_Ambassador (253 ITR 430) sought to be relied by the Ld. AO is distinguishable on facts. In the said case, the assessee wrote off the amount as bad debts in the debtors ledger, after the accounts were finalised and audited. In that context, it was held that deduction under Section 36(l)(vii) cannot be allow .....

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uot; from Section 36(l)(iii), the bad debts written off should be 'irrecoverable'. It was held that since no material has been brought on record to show that the subject debts have infact become irrecoverable, the deduction would not be allowed. However, it is submitted that the aforesaid judgment now stands overruled by the judgment of the Supreme Court in the case of TRF Ltd (Civil Appeal no.5293 of 2003 and 5294 of 2004). Reliance is also placed on the judgments of the Gujarat High Co .....

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by the CBDT. By way of the said circular, it has been clarified that a mere write off in the books of the Company is adequate for claim of bad debts u/s.36(1)(vii) of the Act. Submissions dated July 9, 2012 was filed where it was indicated that Provision for bad debt (through which the subject bad debt were written off) have been offered to tax in prior years. The bad debts are genuine and vouched by the auditors of the Company. The auditors have formed an opinion that the accounts reflect a tru .....

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u/s 29 of the Act. Deduction should be allowed in the year in which the provision was created and offered to tax Provision for bad debts was offered to tax in the preceding years in which the said provision was created and charged to profit and loss account. Disallowance of bad debts written off in the current year would tantamount to double disallowance. Hence, in the event, bad debt is disallowed in the current year, deduction should be allowed with regard to provision created in the precedin .....

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er (Appeals) shall have the following powers - (a) in an appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment (emphasis added). However, some decisions have been rendered wherein the power of enhancement was sought to be restricted by holding that such enhancement would not apply to sources of income which had not been considered by the Assessing Officer -CIT, Bombay v. Shapoorji Pallonji Mistry (1962) 44 ITR 891 (SC). However, this line of thinking was .....

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ance of the fact that the Appellate Authority had plenary powers in disposing of an appeal and the scope of his power is coterminous with that of the income tax officer. He can do what the income tax officer can do and also direct him to do what he has failed to do. The Court referred to the fact that the Appellate Authority was only subject to the restrictions or limitations, if any, prescribed by the statutory provisions. In the absence of any statutory provisions, the appellate authority is v .....

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2,30,000/- freshly added by the Appellate Assistant Commissioner? (2) Whether the sum of ₹ 2,30,000/- was added by the Appellate Assistant Commissioner on new sources of income of items not considered by the Income Tax Officers from the point of view of assessability? (3) Whether the Appellate Assistant Commissioner had no jurisdiction or power to add the sum of ₹ 2,30,000/- in the facts and circumstances in which he has added the same? (emphasis added). The Court further goes on to .....

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question No. 2 is answered in the affirmative, question nos. 1 and3 must be answered in the negative. The appeal is therefore allowed............ The Apex Courts decision is in tune with the well accepted legal maxim that no word can be read into a statute if it is not clearly so provided. No word which is provided in a statute can also be excluded as meaningless. In other words, there has to be a strict interpretation of the statute as is clear from the wordings: Cape Brandy Syndicate v. IRC ( .....

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Lal and Co. [2002] 251 ITR 864 (Delhi) the High Courts has sought to distinguish the Apex Court decision on the ground that the Apex Court did not deal with a situation where a new source of income was considered by the Appellate Authority for enhancement. In Union Tyres case the Delhi High Court distinguisheded Deluram case by commenting that the Apex Court did not comment on the issue whether the wide powers of the First Appellate Authority also included the power to discover a new source of i .....

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nary powers which the ITO may have while making the assessment, but did not comment on the issue whether these wide powers also include the power to discover a new source of income. Therefore, the principle of law laid down in Shapoorji and Chamaria's cases (supra) still hold the field (para 10 of order). Accordingly, the Delhi High Court held that there was a solitary but significant limitation to the power of revision in that it is not open to the AAC to introduce in the assessment a new s .....

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Court noted that the Apex Court had not specifically approved enhancement where a totally new source of income was the basis for enhancement. It held that: whenever the question of taxability of income from a new source of income is concerned, which had not been considered by the A.O., the jurisdiction to deal with the same in appropriate cases may be dealt with u/s. 147 / 148 of the Act and section 263 of the Act, if requisite conditions are fulfilled. It is inconceivable that in the presence o .....

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lear from the fact that enhancement based on new source of income had been considered and approved by the Apex Court in Deluram's case et al, and quite clear from the reproduction from that case noted earlier. It is also worth noting that if the wording in section 251(1)(a) read as under: In respect of issues in appeal, he may confirm, reduce, enhance or annul the assessment, then, the interpretation given by the various High Courts may perhaps have been relevant. We have also noted that a s .....

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se facts would also show that there is no restriction intended on the enhancement power of the Commissioner (Appeals). In this view of the matter, it is submitted that the decision of the Apex Court has not really been distinguished by the Delhi High Court decisions cited. The enhancement done by the CIT(A), in any case is also relating to the same source of income, that is business income. Hence, on any basis, the enhancement is within the parameters provided by the statute and the laid down pr .....

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acted contrary to the settled law. Secondly, the contention of the assessee is that during the year under consideration, the subject bad debts have been credited to the debtor s account with a corresponding debit to the Provision for bad debt account . This in itself would demonstrate that the subject debts have been written off from the ledger of the debtor. It is also contended that in the current year the debt has become bad and has been written off as irrecoverable in the books of accounts o .....

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ce is against the settled legal principle of quando aliquid prohibetur, prohibetur at omne per quod devenitur ad illud . 6.1. the ld.CIT(A) proceeded on the basis that the assessee has not complied with the statutory requirement of section 36(1)(vii), therefore first we would examine whether the ld.CIT(A) was justified in holding that there is a non-compliance of the provisions of section 36(1)(vii) r.w.s.36(2) of the Act; thereby the claim of bad debt could not have been allowed. Undisputedly, .....

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d to profit and loss account. The disallowance of bad debts written off in the current year would tantamount to double disallowance. The Reliance is placed on judgement of the Hon ble Apex Court rendered in the case of TRF Ltd. vs. CIT reported at (2010) 323 ITR 397 (SC). We find force into the contention of ld.counsel for the assessee. The Hon ble Supreme Court in the case of TRF Ltd. vs. CIT(supra) has held as under:- 4. This position in law is well-settled. After 1st April, 1989, it is not ne .....

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ucted from sundry debtors. As stated above, the AO has not examined whether, in fact, the bad debt or part thereof is written off in the accounts of the assessee. This exercise has not been undertaken by the AO. Hence, the matter is remitted to the AO for de novo consideration of the above-mentioned aspect only and that too only to the extent of the write off. 6.2. Therefore, in the light of the recent judgement of the Hon ble Apex Court rendered in the case of TRF Limited v. CIT(supra) the AO i .....

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, therefore, the same are decided together. The respective representatives of the parties reiterated their arguments as were made in the written submissions filed by them. 8. We have heard the rival submissions, perused the material available on record and gone through the orders of the authorities below. We find that the ld.CIT(A) has decided this issue in paras-13.3 to 13.15 of his order by observing as under:- 13.13 In view of above submission of the appellant, now the question arises whether .....

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cost of raw-material of the comparables to arrive at adjusted value of the total purchases of the appellant so that costlier local purchases do not colour the appellant s transaction with AE s. Hence, the entire raw-material cost was reduced to bring Industry at level. The TPO observed that the local raw-material purchases of the appellant was very high (65.99%) and due to these higher local cost of purchase, its results were not comparable with local comparables. It was also observed by the TPO .....

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he tested party and comparable companies and by proceeding to compute the raw-material adjustments. Thus in my opinion the same method/approach should be followed in the case of appellant for A.Y. 2004-05 also which is the year under consideration. It is pertinent to mention that if the adjusted cost of rawmaterial is calculated on the basis of sales turnover, then the cost of raw-material will also include the profit margin of sales, which increases the adjusted cost of raw-material which in tu .....

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ional Net Margin Method benchmarks net profitability, i.e. it tests net profits earned in controlled transactions and compares them to the net profits earning in uncontrolled transactions. That means that instead of gross profit the transactional net margin method analysises the net profits in relation to an appropriate base such as costs, sales, or, as the case may be assets. This is done via net margins or so called profit level indicators. In contrast to the cost plus method, which generally .....

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rable company and accordingly by making adjustment to the raw-material expenses of the comparable companies. I, therefore, hold that this method/approach is required to be followed in the case of appellant for AY 2004-05 also and in doing so there will be Transfer Pricing Adjustment of ₹7,62,29,166/-. In view of this, the AO is directed to follow the above method/approach for AY 2004-05 and to make transfer pricing adjustment on account of Arm s Length Price at ₹7,62,29,166/- in the .....

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t with regard to International Transactions entered into with AE in view of the reasons as discussed above and therefore the penalty proceedings u/s.271(1)(c) of the IT Act are also initiated on enhanced income of ₹.5,50,73,555/- for filing of inaccurate particulars of income. 8.1. The submissions of the ld.counsel for the assessee are reproduced hereunder:- B. ARGUMENTS BEFORE THE HON'BLE TRIBUNAL (Ground No. 3.1 and 3.4): Ground No. 3.1: That the learned CIT(A) has erred in computing .....

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4. These Grounds are not sought to be pressed as the same have already been dealt with and resolved in terms of the CIT(A) rectification order dated October 25, 2012. [Refer Page 1 to 8 of the Paperbook (CIT(A) rectification order)]. Ground 3.3: Without prejudice to the above the learned CIT(A) has erred in not appreciating the error made by the learned Transfer Pricing officer in computing the raw material adjustment and the consequent operating margin of the Appellant Company. 15. The Appellan .....

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rned TPO computed the raw material adjustment as 18.50% of costs as against sales. The TPO followed an incorrect approach by comparing the raw material adjustment to operating cost ratio of tested party vis-avis the raw material to cost ratio of each comparable company and accordingly making an adjustment to the raw material expense of the comparable company. Without prejudice to the approach adopted by the TPO for the raw material adjustment, the computation of the raw material adjustment perfo .....

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national transaction to total costs Particulars Amount (In INR) Amount (In INR) Income Income from Operations 1,045,039,761 Expenditure Total expenses (excluding raw material cost) 417,262,348 Total Material Cost 709,346,049 Less: Downward Adjustment of materials cost as per material cost of comparables (1,045,039,761*18.50%) 193,332,356 516,013,693 Total Expenditure (after adjustment for raw material cost) 933,276,041 Revised Profit 111,763,720 Adjusted OP/ Sales 10.69% 18. As is evident from t .....

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ed while computing the raw material adjustments of the Appellant Company and the comparable companies in the manufacturing segment of the PCDTA division and consequently arriving at the revised operating margin of comparable companies. Use of appropriate base' / Selection of PLI 19. The Appellant submits that the raw material adjustment is computed by the Ld. TPO by comparing the raw material ('RM') to operating cost ('OC') ratio of the tested party vis-a-vis the raw material .....

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saction to determine the arm's length outcome of the price in the controlled transaction. 22. Thus it is undisputed that Sales is the appropriate base for the purposes of the PLI in the instant case. Use of 'appropriate base' for computation of raw material adjustment 23. The Appellant submits that, the Ld. TPO has technically erred in carrying out the mathematical computation of the raw material adjustments in the manufacturing segment of the Power Controls division of GEIIPL for AY .....

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r of test. Accordingly, the raw material adjustment should also be computed having regard to the same relevant base and comparing the RM / Sales ratio of the tested party with the RM / Sales ratio of the comparable companies. 25. In this regard the relevant extracts of the Rule 10B(e) of the Income-tax Rules, 1962 are reproduced below for immediate reference: "transactional net margin method, by which,- (i) the net profit margin realised by the enterprise from an international transaction e .....

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transactions is adjusted to take into account the differences, if any, between the international transaction and the comparable uncontrolled transactions, or between the enterprises entering into such transactions, which could materially affect the amount of net profit margin in the open market; (iv) the net profit margin realised by the enterprise and referred to in sub-clause (i) is established to be the same as the net profit margin referred to in sub-clause (iii); (v) the net profit margin t .....

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s applied relative to an appropriate base, for example costs, sales or assets (see paragraph 2.58 of the Guidelines). If the appropriate base is sales, for example, then any differences in working capital levels should be measured relative to sales." Para 2.58: "The transactional net margin method examines the net profit relative to an appropriate base (e.g. costs, sales, assets) that a taxpayer realizes from a controlled transaction (or transactions that are appropriate to aggregate u .....

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rolled transactions, i.e. by reference to "internal comparables" (see paragraphs 3.27-3.28). Where this is not possible, the net margin that would have been earned in comparable transactions by an independent enterprise ("external comparables") may serve as a guide (see paragraphs 3.29-3.35). 27. ln this regard the Appellant submits that under TNMM the net profit margin realised by the enterprise from an international transaction entered into with an Associated Enterprise (&# .....

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reference to the same relevant base (i.e. Sales). Adopting a different, controlled base, would vitiate the analysis by considering the very transaction which is the subject matter of test for the purpose of the adjustment. 29. Thus in the present case, the raw material adjustments in the manufacturing segment of the Power Controls division of GEIIPL have to be computed by comparing the ratio of raw material costs to sales of the tested party with the ratio of raw material costs to sales of the .....

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s-a-vis the comparable companies. Attention is drawn to the reference made in the Ld. TPO's order for AY 2005-06 (para 6.7 Page 7 line no 5) attached herewith as Annexure 1, wherein the Ld. TPO has made a reference to the raw material ratio of the tested party of '65.99%' which is actually the RM / Sales ratio of the tested party. 31. Further the Ld. TPO has also made a reference to RM / Sales ratio of the comparable companies as well (para 6.8 on page 7 of the TP order for AY 2005-0 .....

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Appellant submits that the raw material adjustment has to be computed with sales as the relevant base and accordingly has computed the raw material adjustments. The Appellant provides the computation of the raw material adjustment and consequently the adjusted operating profit margin of the companies as considered by the Ld. TPO in the Order dated December 22, 2006 for AY 2004-05 as Annexure 2. 35. The arithmetical mean of the adjusted operating profit margin of the comparable companies^ after a .....

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)= (A)*(E) (122,583,164) Adjustment (G) =(F) - (B) Nil 37. Evidently, the operating profit margin earned by Appellant at (7.81)%, is higher than the arithmetical of the adjusted operating profit margin of the comparable companies (post adjustment for raw material costs) of (11.73)%. Accordingly, this lends support to the fact that the international transactions of the Appellant in the manufacturing segment of Power Controls division continue to be demonstrated to be at arm's length even as p .....

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ding unusual expenses incurred by the division during the year [and only 17% of the total material costs]. The workings have been provided in the Table below. Computation of the proportion of international transaction to total costs Calculation of % of AE Transactions to Total Cost AE transactions 121,269,639 Total Costs 1,126,608,397 % of AE Transactions to Total Cost 10.76% Computation of the proportion of international transaction to total raw material costs Calculation of % of AE Transaction .....

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e international transaction with associated enterprises of the manufacturing segment for FY 2003-04 vis-a-vis the total expenses, without prejudice and assuming without admitting, it is contended that any such adjustment, if at all, could have been made only on a proportionate basis i.e. ratio of the material cost from related parties to total material costs or ratio of the material cost from related parties to total costs. Thus the adjustment ought not, in any case, to have exceeded the proport .....

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on of the proportionate adjustment that could have been considered even if one were to make any adjustment to the transfer prices, based on the learned TPO's own faulty approach. 42. The TP adjustment as computed by the learned TPO is given in the table below: Adjustment as computed by the TPO Particulars Arm's length at adjusted RM as per the TPO (Rs.) Total Income from operations 1,045,039,761 AE transactions- Imports from GE entities and Royalty (Balancing Figure) 100,114,028 Material .....

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ual total costs ratio 10.76% 21,155,611 2,276,343 Actual AE costs to actual total material costs ratio 17.10% 21,155,611 3,617,609 44. Based on the above, in summary, the Appellant contends that for the reason that the international transaction value is miniscule to the total costs of the segment, it would be highly unreasonable to attribute the entire difference, between the arithmetical mean of the OPM of the comparable companies vis-a-vis the OPM of the manufacturing segment of PCDTA, to the .....

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anufacturing segment of PCDTA under section 92C(4) read with subsections (3) and (4) of section 92C(3), the domestic industrial business division of the Appellant. 8.2. On behalf of the Revenue, the submissions are as under:- That the learned CIT(A) has erred in computing the Transfer Pricing adjustment of ₹ 7,62,29,166 for the manufacturing segment of Power Control Domestic Tariff Area ('PCDTA') division of the Appellant Company. TPO's Comments: This is a general ground of app .....

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appropriate method and PL1 margin of tested party was worked out to (-) 7.81%(OP/Sales) whereas the PL1 margin of the comparables selected by the assessee was 6.78%(OP/Sales). Since the difference between PLI margin of the tested party and the comparables was beyond 5% variation, the adjustment was worked out to ₹ 15,23,80,530/-. However, the value of international transaction shown by the assessee was ₹ 12,12,69,639/-, therefore TPO did not adopt this amount of ₹ 15.23 crores .....

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the margin of raw material to sales in the case of comparables which was worked out to 49.38%, whereas the margin of raw material with sales in the case of assessee was worked out to 67.88%. Thus it was found that cost of raw material of the assessee was more by 18.50% as compared to comparables. Accordingly the adjustment was made to the cost of raw material of the assessee and the OP/Sales margin of the assessee was worked out to 4.75%, whereas the ALP margin was 6.78%. After applying the ALP .....

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wever, it was found action of TPO making adjustment to eliminate the difference as per Rule 10B(e)(iii) in the case of assessee was found incorrect by the CIT(A) because as per Rule 10B(e)(iii) adjustment was required to be made in the case of comparables. Accordingly, the CIT(A) enhanced the adjustment to ₹ 7,62,29,166/-. The relevant portion of the CIT(A)'s order (page No. 204 & 205, para 13.13 to 13.15 of CIT(A)' order) is reproduced as under:- "13.13 In view of above s .....

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of the appellant and hence it was decided to mark up the cost of raw-material of the comparables to arrive at adjusted value of the total purchases of the appellant so that costlier local purchases do not colour the appellant's transactions with AE 's. Hence, the entire rawmaterial cost was reduced to bring at industry level. The TPO observed that the local raw material purchases of the appellant was very high (65.99%) and due to these higher local cost of purchases, its results were not .....

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ted correct method by considering RM/operating expenses ratio of the tested party and comparable companies and by proceeding to compute the raw-material adjustment. Thus in my opinion the same method/approach should be followed in the case of appellant for AY 2004-05 also which is the year under consideration. It is pertinent to mention that if the adjusted cost of raw-material is calculated on the basis of sales turnover, then the cost of raw-material will also include the profit margin of sale .....

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lus Method and the Resale Price Method. However, the Transactional Net Margin Method benchmarks the net profitability, i.e. it tests the net profits earned in controlled transactions and compares them to the net profits earning in uncontrolled transactions. That means that instead of gross profit the transactional net margin method analyses the net profits in relation to an appropriate base such as costs, sales or as the case may, assets. This is done via net margins or so called profit level in .....

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awmaterial to operating cost ration of each of the comparable company and accordingly by making adjustment to the raw-material expenses of the comparable companies.!, therefore, hold that this method/approach is required to be followed in the case of appellant for AY 2004-05 also and in doing so there will be Transfer Pricing Adjustment on account of Arm's Length Price at ₹ 7,62,29,166/- in the case of appellant." (iii) In view of the above facts, the general ground raised by the .....

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accordingly revised operating margins of the comparables was worked out. The assessee has claimed that C1T(A) has computed raw material adjustment using operating cost as the base and has arrived the revised TP adjustment of ₹ 5,50,73,595/- being the difference between the arithmetic mean of adjusted OPM of (-) 2.54% of the comparable companies and OPM of (-) 7.81% of the assessee (tested party). The claim of assessee that CIT(A) has used operating cost as base is incorrect. The C1T(A) ha .....

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y the adjusted average margin of profit to sales of the comparables was revised at 1.22% as against 9.93%. Accordingly, the downward adjustment of ₹ 2,28,56,144/- was made to the international transaction of purchases of raw material from AE. In view of the above facts, it can be seen that during AY 2005-06, the TPO had taken the base of PLI as OP/Sales while computing the adjustment to be made to the value of international transaction shown by the assessee. The CIT(A) has made the upward .....

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material is calculated on the basis of sales turnover, then the cost of raw-material will also include the profit margin of sales, which increases the adjusted cost of raw-material which in turn will reduce the actual profit margin which is not correct and not comparable. The correct method/appropriate base to calculale the adjusted cost of raw-material proportionate to the total operating cost. The element of profit is to be eliminated or not to be considered while calculating the adjusted cost .....

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dology for working out the adjustment to be made to eliminate the differences on account of cost of raw material by taking the ratio of cost of raw material to total expenses to avoid the effect of profit involved in the sales. This methodology is discussed in the earlier para(underlined portion). The calculation of raw material adjustment of (-)2.54% is mentioned by the CIT(A) in the order u/s 154 dated 25.10.2012. A copy of relevant page of order u/s 154 is attached as per annexure-A. In view .....

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of 10.69% margin worked out by the assessee is reproduced as under: Particulars Amount(lNR) Amount(INR) Income Income from operations 104,50,39,761 Expenditure Total Expenses(Excluding raw material cost) 41,72,62,348 Total material cost 70,93,46,049 Less: Downward adjustment of material cost of comparables (104,50,39,761*18.50%) 19,33,32,356 51,60,13,693 Total expenditure(after adjustment for raw material cost) 93,32,76,041 Revised profit 11,17,63,720 Adjusted OP/Sales 10.69% It can be seen fro .....

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he cost of raw material at industry level. Therefore, TPO had reduced the cost of raw material by 18.50% of the assessee. However, the assessee has worked out the downward adjustment by taking the sales figure which is totally incorrect method. As already pointed out by the CIT(A), adjustment was required to be made in the case of comparable as per Rule 10B(e) (iii) to eliminate the differences in the cost of material, the action of TPO in making adjustment in the hands of tested party to elimin .....

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39;s comments: The claim of assessee is correct. However, the C1T(A) has already passed rectification order on 25.10.2012 through which the above mathematical error has been rectified and the revised adjustment is worked out to ₹ 5,50,73,555/- (TP adjustment made by TPO of ₹ 2,11,55,611/- + enhancement made by CIT(A) of ₹ 3,39,17,984/-). Therefore, this ground of appeal is redundant . 9. We have given our thoughtful consideration to the rival submissions made by the respective .....

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Loss/Sales -7.81% 10. The TPO noticed that as per list of comparables provided by the assessee, the operating margin of the comparables was 6.78%, as under:- i.b.1 The assessee had provided a list of comparables the same is provided as under:- S.No. Name of Comparables Operating Profit Margin 1 Bhartia Industries 1.72% 2 Controls & Switchgear Contractors Ltd 5.77% 3 Crompton Greaves Ltd 4.41% 4 Lakshmi Electrical Control Systems Ltd 10.35% 5 Havells India Ltd. 7.47% 6 Incap Ltd 5.72% 7 Indo .....

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s 49.38%, but in the case of the assessee, it was 67.88%. Thus, there was difference of 18.50%. The TPO allowed the adjustment therefor while making the revised calculation of margin. After adjustment of cost of raw material, the operating profit of the assessee on sales was worked out to 4.75%, as under:- i.c. 2 The margin of raw material to sales of the assessee was also computed which was then compared to find out the incremental cost of raw material incurred by the assessee. The calculation .....

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nward adjustment of material cost as material cost of competitors are less 131,224,919 578,121,130 (709,346,049 * 18.50%) Revised Total expenditure 995,383,478 Revised Profit/Loss 49,656,283 OP/Sales 4.75% 12. At the time of hearing before us, it was pointed out by the ld. Counsel that while working out the consumption of raw material by the assessee as well as comparables, the Assessing Officer worked out the ratio by dividing raw material to the sales, which would be evident from the following .....

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, the TPO compared the raw material of the assessee as well as comparables by dividing the cost of raw material to the sales. But, while giving the adjustment, the TPO allowed the adjustment of 18.50% of the total material cost and not of the sales. Therefore, the only request before us from the assessee s side was to allow the adjustment of the 18.50% on sales. We find that the CIT(A), while adjudicating this issue, has considered the order of the TPO for Assessment Year 2004-05 as well as Asse .....

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should be followed in the case of appellant for A.Y. 2004-05 also which is the year under consideration…. 14. After considering the arguments of both the sides, we are of the opinion that the CIT(A) was not justified in giving any opinion about the correctness or otherwise of the TPO s order for Assessment Year 2005- 06, because that was not under appeal before him. However, be that as it may be, we have heard both the parties with regard to the method to be followed while comparing the r .....

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The denominator should be reasonably independent from controlled transactions, otherwise there would be no objective starting point. For instance, when analyzing a transaction consisting in the purchase of goods by a distributor from an associated enterprise for resale to independent customers, one could not weight the net profit indicator against the cost of goods sold because these costs are the controlled costs for which consistency with the arm s length principle is being tested. Similarly, .....

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ise), caution should be exercised to ensure that said controlled transaction costs do not materially distort the analysis and in particular that they are in accordance with the arm s length principle. 2.89 The denominator should be one that is capable of being measured in a reliable and consistent manner at the level of the taxpayer s controlled transactions. In addition, the appropriate base should be one that is capable of being measured in a reliable and consistent manner at the level of the .....

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enterprise for resale to independent customers. In such cases, the sales figure at the denominator should be the re-sales of items purchased in the controlled transaction under review. Sales revenue that is derived from uncontrolled activities (purchase from independent parties for re-sale to independent parties) should not be include in the determination or testing of the remuneration for controlled transactions, unless the uncontrolled transactions are such that they do not materially affect .....

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e the service activity is performed using rights or other assets that are granted under the distribution arrangement. See also discussion of portfolio approaches in paragraph 3.10. 15. In the instant case, what is being tested is whether purchase from associated enterprises is at arms-length or not. Admittedly, sales by the assessee is not to the associated parties and therefore, is un-controlled transaction. In view of above, in the light of OECD guidelines, while working out ratio of raw-mater .....

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ct the Assessing Officer to allow the adjustment of 18.50% of the sales while working out the operating profit and if, after the above adjustment, the operating profit of the assessee works out to more than 6.78% i.e. the average of operating profit of comparables, then no adjustment should be made. With this direction, we set aside the orders of the lower authorities and restore the matter back to the file of the Assessing Officer. 16. Before parting with the matter, we hereby clarify that our .....

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for AY 2004-05, wherein following grounds have been taken:- 1. On the facts and in the circumstances of the case and in law, the learned CIT(A) has erred in allowing set off of the business loss of ₹ 2,64,32,995/- pertaining to AY 1997-98 against profit of AY 2004-05 without considering the fact that as on 31.03.1997, GE Padific Ltd., Singapore alone was able to control GE Lighting Division i.e. assessee company, but after merger, it had lost the controlling power as its number of share ho .....

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(A) was justified in allowing set off of the business loss. The ld.CIT-DR submitted that the ld.CIT(A) was not justified in allowing the set off of the business loss of ₹ 2,64,32,995/- pertaining to AY 1997-98 against profit of AY 2004-05 without considering the fact. He submitted that the ld.CIT(A) ought o have upheld the order of the AO. He placed reliance on the order of the AO. 19.2. On the contrary, ld.counsel for the assessee submitted as under:- At the outset it is submitted that th .....

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ted in Section 79 of the Act. Section 79 requires an inquiry to be made as to who the shareholders were at two points in time i.e on the last day of the previous year in which the losses are set off and on the last day of the previous year in which the losses were incurred. On identification of persons/ shareholders at two points in time, it must be ascertained what their share holding in the company is at two points in time. Section 79 refers to "persons" in plurality. The reference i .....

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in 'The law and practice of Income-tax, Eighth Edition, Volume 1, commentary by Chaturvedi and Pithisaria in Income Tax Law, 2nd Edition, vol 2, Page 1150. In the instant case, as evident from the shareholding pattern, and admitted by the Ld. AO as well as Ld. CIT(A) that GE Pacific Pte Ltd, Singapore and GE Pacific (Mauritius) Ltd collectively continued to hold more than 51% of the shares of the Company in the year ended March 31,1997, (the years in which losses were incurred) and March 31 .....

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company as long as General Electric continues to have control over it through its subsidiaries. The ultimate beneficiary interest remains within the GE group. Reliance on Bangalore Tribunal Ruling in the case of Amco Power Systems Limited and Delhi Tribunal Ruling in the case of Select Holiday Resorts Pvt. Ltd. 20. We have heard the rival submissions, perused the material available on record and gone through the orders of the authorities below. We find that the ld.CIT(A) has given a finding on .....

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4-05. Rather the AO has stated that the appellant was once again called upon to furnish details of company-wise losses which merged into the appellant company and the share holding pattern of such companies in the year of incurrence of losses. The AO has further stated that the contention of the appellant is not correct as it itself has claimed the benefit of carried forward and setting off of the losses and therefore, it is obligatory upon it to substantiate the claim specifically in light of t .....

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considered for the purpose of allowing or disallowing the same u/s.79 of the IT Act against the profit of 2005-06. These facts show that the AO has contradicted himself by stating that the appellant was called upon to furnish details of company-wise losses and share holding pattern of such company in the year of incurrence of losses during the course of assessment proceedings of AY 2005-06. The very fact is that the appellant has claimed carry forward and set off of part of the losses against th .....

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