D.C.I.T. 2(1), RAIPUR vs. M/S BAGADIYA BROS. PVT. LTD., RAIPUR

Appeal is dismissed

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Method (TNMM). The results were accepted by AO/TPO as within ALP. In respect of export of Iron Ore Fines, the uncontrolled comparable transactions were identified in TP Study using internal export instances in case of assessee as well as import instances by AE. Further, the external comparable instances were identified using data from Trade Steel Index (TSI) and U-Metal