TMI Blog2016 (8) TMI 1287X X X X Extracts X X X X X X X X Extracts X X X X ..... would radically undergo change. Pertinently, for the previous year 2006-07, the assessee’s comparables – including some of those which were rejected in the present order, were in fact accepted when the matter reached finality. In these circumstances, the interpretation adopted by the AO was plainly erroneous. The Court is also of the opinion that in the absence of any overt act, which disclosed co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Sh. R. Satish Kumar, Advocate. O R D E R The present appeal against the order dated 08.08.2016 of Income Tax Appellate Tribunal is barred because the revenue has refiled it with a delay of 550 days. On this ground alone, the appeal is liable to be rejected. This Court has considered the merits of the appeal as well. The brief facts are that during the relevant period, i.e. AY 2007-08, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he assessee in this case could not, in the opinion of this Court, visualize that out of the twelve comparables furnished, nine would be rejected and the matrix of calculations, as it worked, would radically undergo change. Pertinently, for the previous year 2006-07, the assessee s comparables including some of those which were rejected in the present order, were in fact accepted when the matter ..... X X X X Extracts X X X X X X X X Extracts X X X X
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