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Income Tax Appellate Tribunal, DELHI ‘I-1’ BENCH,
Before: SHRI SAKTIJIT DEY, & SHRI N.K. BILLAIYA
PER N.K. BILLAIYA, ACCOUNTANT MEMBER:-
This appeal by the Revenue is preferred against the order dated 17.02.2015 framed under section 143(3) r.w.s 144C(13) of the Income- tax Act, 1961 [hereinafter referred to as 'The Act'] pertaining to Assessment Year 2010-11.
Grievance of the Revenue reads as under:
“On the facts and circumstances of the case the ld. DRP has erred in directing the TPO to recomputed the addition on account of transfer pricing adjustments by excluding/including certain companies without appreciating fully the functional comparability of such companies.”
A perusal of our record shows that on 20.11.2019, the CIT-DR sought time to file revised grounds of appeal. Thereafter, successive adjournments were taken by the CIT-DR. On 11.11.2021, the CIT-DR was directed to file specific grounds with respect to inclusion and exclusion of comparables. Till date, no such action has been taken by the Revenue. Therefore, we are left with no choice but to proceed with the grounds of appeal mentioned hereinabove.
In our considered opinion, the ground of appeal taken by the Revenue [supra] is cryptic and non-specific. We, therefore, dismiss this appeal by the Revenue on such cryptic and non-specific ground of appeal. However, the Revenue is at liberty to approach the Tribunal as per the provisions of law with specific grounds of appeal.
In the result, appeal of the Revenue in is dismissed.
The order is pronounced in the open court on 11.01.2022 in the presence of both the representatives.