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TMI Blog2022 (12) TMI 156X X X X Extracts X X X X X X X X Extracts X X X X ..... facturing of Fiberglass Reinforced Polymer Composite Products and Resins. The return of income for the year under consideration was filed by it on 30/09/2009 declaring a total income of Rs.11,52,94,990/-. The said return was selected for scrutiny under CASS and a notice u/s.143(2) of Income Tax Act, 1961 (hereinafter referred to as "the Act") was issued by the Assessing Officer to the assessee on 18/08/2010 and 24/08/2010. As noted by the Assessing Officer during the course of assessment proceedings, the assessee-company had entered into International Transactions with its Associated Enterprises (AEs), aggregate value of which exceeded Rs.5 crores. He, therefore, made a reference to the TPO u/s.92CA of the Act for determining the Arm's Leng ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... changed by the TPO to operative profit to operative cost. Accordingly, the PLI of the assessee-company was computed by the Assessing Officer at 02.80% as against the PLI of the comparables calculated at 08.10% and a Transfer Pricing adjustment of Rs.5,48,31,917/- was determined by the TPO. In the assessment made by the Assessing Officer u/s.143(3) of the Act read with section 144C(1) of the Act vide an order dated 18/03/2013, an addition to that extent as determined by the TPO was made by the Assessing Officer to the total income of the assessee on account of Transfer Pricing adjustment. 3. The addition made by the Assessing Officer on account of Transfer Pricing adjustment was challenged by the assessee in appeal filed before the Ld.CIT(A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Technologies (P.) Ltd. vs. DCIT, Circle-1(1), New Delhi reported in (2015) 57 taxmann.com 10 (Delhi Trib). Aggrieved by the order of the Ld. CIT(A), the Revenue has preferred this appeal on the following ground: "On the facts and in the circumstances of the case and in law, the Ld.CIT(A) erred in law and fact in holding that the adjustment should be restricted to the turnover of the assessee company relating to the sale of resins to its AEs only." 4. At the time of hearing fixed before the Tribunal, none has appeared on behalf of the assessee. There was a similar non-compliance on the part of the assessee even when this appeal was earlier fixed for hearing on various occasions. Therefore, this appeal of the Revenue is being disposed of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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