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TMI Blog2019 (8) TMI 167X X X X Extracts X X X X X X X X Extracts X X X X ..... f the transfer price for international transactions in the Assessee s manufacturing and installation segment - HELD THAT:- ITAT differed from the view expressed by the TPO and accepted the reasoning put forth by counsel for the Assessee that the finances of the three comparables which included ITI Ltd., with reference to their respective annual reports, did show that there was a general trend in t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... O R D E R CM APPL. 33398/2019 (Delay) 1. For the reasons explained in the application, the delay in re-filing the appeal is condoned. Application is disposed of. ITA 692/2019 2. The Revenue is in appeal against an order dated 9th February, 2018 passed by the Income Tax Appellate Tribunal (ITAT) in ITA No. 1618/Del/2018 for the Assessment Year ( AY ) 2005- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erved that the financing of ITI by the Government indicated that it was unable to compete effectively in the market. Further, the questions of autonomy and other factors made PSUs generally incomparable, as their working was not influenced by market conditions. 5. The ITAT differed from the view expressed by the TPO and accepted the reasoning put forth by counsel for the Assessee that the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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