Bench: Shri George Mathan & Shri Rakesh Mishra
Transfer Pricing Audit proceeding before the TPO and thereby violates Rule 46A of the Income Tax Rules, 1962. 14. That the appellant craves leave to add to and/or alter, amend, modify or rescind the grounds hereinabove before or hearing of this appeal.” 2.1. The assessee is also in appeal before the Tribunal raising the following grounds of appeal