In the result, these three appeals filed by the Revenue are dismissed
Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.176 To 178/Srt/2022 Assessment Years: (2012-13 To 2014-15) (Physical Hearing) The Acit, Central Circle-3, Vs. Antrix Diamond Exports Pvt. Ltd., Surat. 1006, Free Press Mark, Raheja Centre Nariman Point, Mumbai – 400021. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaca3403G (Revenue)/(Appellant) (Assessee)/(Respondent) Assessee By Ms Ekta Sanghvi, Ca Revenue By Shri Ashok B. Koli, Cit(Dr) Date Of Hearing 10/02/2023 21/03/2023 Date Of Pronouncement
TP proceedings, the assessee justified the TNMM by comparing its profits margins with the margins earned by third parties engaged in similar activities. However, it was noted that assessee did not furnish the correct amount of profit earned from the two international transactions entered into with the AE. Despite the fact that the assessee was requested to provide the actual