M/S.JOY ALUKKAS INDIA P. LTD,TRICHUR vs. THE ACIT, ERNAKULAM
In the result, the appeal filed by the Assessee stands partly allowed for statistical purposes
ITA 119/COCH/2016[2011-12]Status: DisposedITAT Cochin08 Sept 2025AY 2011-12
Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)
For Appellant: Smt. Parvathy Ammal, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 36(1)(iii)Section 36(1)(viii)Section 92C
92A(2), but went on confirm the upward revision towards TP adjustment proposed by the ΤΡΟ.
4. The Dispute Resolution Panel is erred in not appreciating the fact that the data relied on by the transfer pricing officer was not available in public domain while carrying out its TP documentation and hence such data should not have been considered
