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2024 (1) TMI 1274 - DELHI HIGH COURTTP Adjustment - MAM - selection of comparables - HELD THAT:- We find that the appeal raises the following substantial questions of law:- a) Whether the Income Tax Appellate Tribunal [‘ITAT’] has erred in holding that the CIT(A) erred in making 5% adjustment? b) Whether the ITAT has erred in holding that the CIT(A) was precluded from applying internal CUP as the most appropriate method applicable to 8K Cards and could have only applied the Re-Sale Price Method? c) Whether the ITAT has erred in upholding the method of benchmarking of each product segment of the Appellant against the comparable companies at entity level? d) Whether the ITAT has erred in entirely ignoring the alternative submissions made vide letter dt. 18.9.2021 under Rule 27 of the ITAT Rules, 1962 regarding the incorrect selection of comparables? The respondents are accorded liberty to file their Written Submissions on the record within a period of three weeks from today. Those submissions shall refer to the pdf page numbers of the digital record of the Court wherever so required. Let the appeal be called again on 01.05.2024.
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