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TMI Blog2022 (3) TMI 1482X X X X Extracts X X X X X X X X Extracts X X X X ..... hri Hoshang ORDER PER S. RIFAUR RAHMAN (AM) 1. Through this Miscellaneous Application assessee requested to recall the ITAT order in ITA.No. 1537/Mum/2016 (A.Y. 2011-12) dated 10.01.2020 pertaining to Ground Nos. 1 and 2 and consider the same in accordance with law. 2. At the time of hearing, Ld. AR of the assessee submitted that with reference to Page No. 3 of the ITAT order wherein the co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t was inadequate. The department / respondent also do not contend that the comparables were inadequate. They have analyzed the same in a particular manner whereas the CIT (A) has analyzed the same in a different manner. In other words, the respondent has not contended and the Tribunal had not held that the relevant comparables are insufficient." 3. With reference to the above decision of the Hon ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bunal has restored the issue back to the file of the AO/TPO, whereas Ld. AR has pointed that this issue has already been considered by the DRP in A.Y. 2012-13 and the copy of the order is placed on record at Page No. 116 of the Paper Book. He submitted that all the relevant information were already placed before the ITAT. After considering the submissions, we observe that there is a mistake appare ..... X X X X Extracts X X X X X X X X Extracts X X X X
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