In the result, the appeal of the Revenue is hereby dismissed
Bench: Shri Waseem Ahmed & Shri Soundararajan K
transfer pricing issues having 11 pages, various case laws along with its compilation and contended that the number of employees employed in the year in dispute is far exceeding 10% of the employees as on the last day of the previous year. The ld. AR in support of his contention filed the auditors certificate place on pages