Bench: Shri Waseem Ahmed & Shri Soundararajan K.Us Technology International Pvt. Ltd. Acit, Circle - 1(1) 621, Nila, Technopark Campus 1St Floor, Aayakar Bhavan Vs. Kariyavattom, Trivandrum 695581 Kowdiar [Pan: Aaacu5628B] Thiruvananthapuram 695003 (Appellant) (Respondent)
3 US Technology International Pvt. Ltd. 3.6. The Ld. TPO erred in law in rejecting the Transfer Pricing study maintained by the Appellant by proposing new filters. 3.7. The Ld. AO/DRP erred in law in applying an arbitrary filter to reject companies having related party transactions greater than 25% of sales. The appellant seeks 0%-15% RPT filter as judicially