TMI Blog2015 (2) TMI 1164X X X X Extracts X X X X X X X X Extracts X X X X ..... furnished before the Tribunal by the Respondent Assessee for the first time during the hearing, in violation of Rule 29 of the Appellate Tribunal Rules and these calculations were also not validated by the statutory auditors of the RespondentAssessee? (b) Whether on the facts and circumstances of the case and in law, the Tribunal was right in directing the A. O. to simply verify the calculatio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... practical way?” - INCOME TAX APPEAL NO. 298 OF 2013 - - - Dated:- 16-2-2015 - M.S.SANKLECHA, G.S.KULKARNI, JJ. Mr. A. R. Malhotra with Mr. N. A. Kazi i/b. Ms. Padma Divakar, for the Appellant. JUDGEMENT Heard. 2 Appeal relates to Assessment Year 200405. 3 Appeal admitted on the following reframed substantial questions of law: ( a) Whether on the facts and circumsta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the facts and circumstances of the case and in law, the Tribunal was justified in giving directions to the A. O. to work out the ALP only with respect to international transactions of the Assessee with its AEs though the TNMM analysis was done by the TPO at the entity level as no statutorily audited AE and nonAE segment was available in the audit report of the Assessee and this was done by the A. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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