9911796707
TMI Blog2018 (11) TMI 1580X X X X Extracts X X X X X X X X Extracts X X X X ..... tion was not raised before the TPO, though this contention was raised before the Hon’ble Hon'ble DRP, we find no details of segments of AE and non- AE transactions. The assessee-company had not shown any authority that even under TNMM ALP adjustment should be restricted to AEs only nor the appellant contested the applicability of TNMM method. Thus, it cannot be said that there is a prima facie ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 4/- for the assessment year 2014-15. It is stated in the said petition that the demand in question had arisen on account of arm s length price (ALP) adjustment in respect of international transactions of ₹ 29,60,30,584/-. It is submitted that the Transfer Pricing Officer (TPO) had chosen comparables which are not comparable with that of the assessee-company. It is urged before us that transf ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... demand in question had arisen on account of ALP adjustment in respect of international transaction of ₹ 29,60,30,584/-. The main contention by the learned AR of the petitioner is that ALP adjustment should be restricted to international transaction with its AE. We find from the perusal of the orders of the lower authorities that this contention was not raised before the TPO, though this cont ..... X X X X Extracts X X X X X X X X Extracts X X X X
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