TMI Blog2020 (10) TMI 1170X X X X Extracts X X X X X X X X Extracts X X X X ..... e taken as comparables on the basis of facts of different case for different assessee for different assessment year and directing the TPO to apply RPT filter of 15% - HELD THAT:- As assessee submits that the competent authority of USA and India have reached mutual agreement and on the basis of the aforesaid agreement, the AO has passed an Order giving effect to mutual agreement procedure vide orde ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Income Tax Act, 1961 (hereinafter referred to as 'the Act', for short) has been preferred by the revenue. The subject matter of the appeal pertains to the Assessment Year 2006-07. The appeal was admitted by a Bench of this Court vide order dated 18.01.2016 on the following substantial questions of law: 1. Whether on the facts and in the circumstances of the case, the Tribunal were ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ther, on the facts and in the circumstances of the case, the Tribunal were right in law in directing the TPO to apply RPT filter of 15% instead of RPT of 25%? 3. When the matter was taken up today, learned counsel for the assessee has produced a memo, which is taken on record. Learned counsel for the assessee submits that the competent authority of USA and India have reached mutual agreement ..... X X X X Extracts X X X X X X X X Extracts X X X X
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