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
Transfer Pricing Officer has followed the well searched formula and the data that simple year should have been taken into account. The Ld. DR submitted that the TPO has taken cognisance of the depreciation adjustment and relied upon the order of the TPO and the Assessing Officer. 11. We have heard both the parties and perused all the relevant material