2022 (2) TMI 810

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..... aised in the grounds of Appeal, the Arm Length Price charges would change to 37.5% to 41%, which is still within the tolerance margin of 5% of the TP guidelines. We, by taking note of the concerns expressed by the ld. CIT, DR and make it clear that as a result of the dismissal of the Revenue's appeal on the ground of low tax effect, the said order would not act as a precedent where there .....

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..... rounds for not including the comparables by the A.O. i.e. M/s. Jain Granites Project India Ltd. and M/s. Somany Ceramics Ltd. 3. The representative of the Assessee submitted that, even if both the grounds raised by the Revenue are allowed by including the comparables i.e. M/s. Jain Granites Projects India Ltd. and M/s. Somany Ceramics Ltd. for determining the adjustments made of Arm's L .....

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..... effect, the said order would not act as a precedent where there is a tax effect in any subsequent or prior year where the Revenue would want to agitate the issues on similar grounds before the ITAT on merit. Accordingly, in the light of the submissions of the ld. AR and the DR, the appeal of the Revenue is dismissed. 7. Now we turn to the C.O. No. 06/Del/2020 filed by the assessee. In view o .....

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