Durr India Private Limited, Chennai vs. DCIT, Chennai
In the result, the appeals of the assessee for all the three assessment years are allowed for statistical purpose
ITA 455/CHNY/2016[2011-12]Status: DisposedITAT Chennai21 Dec 2016AY 2011-12
Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]
For Appellant: Mr. Kapil Hirani, Mr. DarpanFor Respondent: Shri. V. Anjaneyalu, IRS, CIT
Section 143(3)Section 144C
…IT (2016) 268 ITR 1022. For his contention that CUP could not be preferred over TNMM in the absence of a comparable, ld. Authorised Representative placed reliance on a decision of Delhi Bench of this Tribunal in the case of Frigoglass India (P) Ltd vs. ACIT, 180 TTJ 265. For his contention that lower authorities ought to have accepted TNMM based on the study done by the assessee, when CUP could not be applied, reliance was placed on a Co-ordinate Bench decision in the case of DCIT vs. M/s. Flakt (India) Ltd, (in ITA 1032/Mds/2014, dated 9.06.2016). According to him there was no requirement for any adjustment…