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TMI Blog2015 (11) TMI 1628X X X X Extracts X X X X X X X X Extracts X X X X ..... ental information without appreciating that under TNMM, broad functional similarity is required to be seen more so as the assessee itself had not furnished audited segmental accounts? (ii) Whether on the facts and in law, the Tribunal was justified in rejecting M/s. Pidilite Industries Ltd.(PIL) as a comparable on the ground of there being a merger and demerger during the year without appreciat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e facts and in law, the Tribunal was justified in rejecting MIL as a comparable on the ground that the Annual Report of MIL did not provide segmental information without appreciating that under TNMM, broad functional similarity is required to be seen more so as the assessee itself had not furnished audited segmental accounts? (ii) Whether on the facts and in law, the Tribunal was justified in r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... LP? 3. So far as the question no. (iii) is concerned, Counsel for both parties state that the issue is covered against the Revenue by the decision of this Court in the Commissioner of Income Tax8 Vs. M/s. Tara Jewels Exports Pvt. Ltd. in Income Tax Appeal No. 1814 of 2013, which was dismissed on 5th October, 2015. In the above view, the issue raised in question (iii) does not give rise to any ..... X X X X Extracts X X X X X X X X Extracts X X X X
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