FARES DADDY PRIVATE LIMITED,HARYANA vs. DC/ACIT TP 1(3)(1) DELHI, CIVIC CENTER

Ground 2: The DRP order is erroneous in law and facts as no direction has been given in the order in relation to comparable rejected by the Ld. TPO on wrong ground of loss making comparable and the same was objected by the appellant before DRP for the arm’s length price determination, resulting in the exclusion of a valid comparable and an incorrect conclusion. 3. Ground 3: The DRP order is erroneous in law and facts as no direction has been given in the order in relation to the exclusion of certain comparable objected before DRP which are failing to meet the legally acceptable criteria for comparability. 4. Ground 4: The Final order of Ld AO and TPO is erroneous in law and facts as the Ld. TPO/AO has failed to provide the working capital adjustments which is in complete violation of the directions by the Hon'ble DRP. 5. Ground 5: The learned AO/TPO erred in wrongly computing the operating margins of some of the comparable companies. 6. Ground 6: The Final Order of the Ld. AO order is erroneous in law and facts in not allowing genuine business expenditure of Rs. 20,48,075 as the same has been passed without considering the evidences of various expenses incurred by the appellant company for the purpose of business. 7. Ground 7. The Appellant craves leave to add, alter, amend or withdraw all or any of the Grounds of Appeal herein and to submit such statements, documents and papers as may be considered necessary either at or before the appeal hearing.”