In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of
Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani
capital adjustment as against 11.91% (which was revised to 14.85%, after depreciation adjustment) margin of the assessee. Since OP/TC margin of the assessee was greater than mean margin of the comparable companies, it was concluded that international transactions of the assessee were at arm’s length. The ITA Nos.179/Ind/2016, 292/Ind/2017, 319/Ind/2018 & SA No.46/Ind/2021 A.Ys