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 study. 4.5 conducting fresh search by rejecting the objections raised by the appellant in relation to selection/rejection/modification of filters or inconsistency in application of filter/s. 4.6 using information obtained under section 133(6) of the Act. 4.7 Considering companies as comparable to the appellant despite such companies failing test of comparability or failure of TPO’s own filer