In the result, appeal filed by the assessee is partly allowed for statistical purposes
Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble
Transfer Pricing matters – Specified Domestic Transactions: Ground No.1: Rejection of CUP and Application of TNMM a) Rejecting the approach / analysis undertaken by the appellant to determine the ALP of the SDT relating to purchase of raw materials or semi-finished goods or finished goods and by products and making an adjustment of Rs. 61,64,747/-. b) Rejecting comparable uncontrolled