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TMI Blog2016 (9) TMI 306X X X X Extracts X X X X X X X X Extracts X X X X ..... f cost. material provided by the Railways to Titagarh Wagons Ltd. as well as to Texmaco Ltd. and thus the said information is necessary to take into account the functions performed, assets employed and risks assumed ("FAR"). Ld. DRP in his finding also has directed Ld. TPO to take these aspects while allowing the said comparables. There is no doubt that these two companies are having the major rol ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... application is disposed of. ITA No. 391/2016 3. This appeal by the Revenue under Section 260A of the Income Tax Act, 1961 ( Act ) is directed against the impugned order dated 4th November 2015 passed by the Income Tax Appellate Tribunal ( ITAT ) in ITA No. 1626/Del/2015 for the Assessment Year 2010-11. 4. The short question that is sought to be urged in this appeal by the Revenue is w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... above submission, the DRP ordered as under: The TPO is therefore instructed to call for the information under section 133(6) about the value of free of cost supplies from Titagarh Wagons Ltd. and if the same is not received within a reasonable period from time barring date, then in that event, subject to the said information being available, the benefit of 30% of the cost should be given on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... es to the Indian Railway and these are proper comparables if all the aspects are taken into consideration including the free of cost material value. Therefore, Ld. TPO is directed to take into account 30% additional cost base to account free of cost' material and revised the OP/TC margin of 13.65% for determining the arm's length margin as claimed by the Assessee. 7. Having heard th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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