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TMI Blog2016 (11) TMI 1732X X X X Extracts X X X X X X X X Extracts X X X X ..... y allowed for statistical purposes. - ITA No. 1453 (Bang) 2010 - - - Dated:- 3-11-2016 - SHRI A. K. GARODIA, ACCOUNTANT MEMBER AND SMT ASHA VIJAYARAGHAVAN, JUDICIAL MEMBER For the Assessee : Shri P.K.Prasad, CA Shri Umashankar, CA For the Revenue : Miss Neera Malhotra, CIT DR ORDER PER SHRI A.K. GARODIA, AM This appeal is filed by the assessee and it is directed against the assessment order passed on 01.10.2010 u/s 143 (3) r.w.s. 144 C of the IT Act, 1961 for A. Y. 2006-07. 2. The Grounds raised by the assessee are as under:- The grounds mentioned herein are without prejudice to one another. General grounds 1.That the order of the learned Deputy Commissioner of Income Tax, Large Tax Payers U ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... m the international transactions undertaken by the Appellant with its Associated Enterprises. (b) Rejecting the profit level indicator, as selected by the Appellant under the Transactional Net Margin Method, for arbitrary reasons, and thereby going against general Transfer Pricing principles. (c) Applying multiple year/prior year data for comparable companies while determining arm's length price. (d) Using data of com parables as at the time of assessment proceedings, instead of that available as on the date of preparing the TP documentation for comparable companies while determining arm's length price. (e) That the learned DRP erred in including companies in the comparability analysis which are different from the Appell ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ate of 60% of Rs.2,469.897 on total expenses of Rs.4,116,495/-) in the computation of total income 9. That the ld., AO erred in not allowing the deduction claimed under Chapter VIA amounting to Rs.100.000 10. (a) That the learned AO erred in computing the interest under section 234B without considering the provisions of this section. (b) That the AO erred in adjusting the interest due under section 234C against the self assessment tax in arriving at the tax liability on which interest is to be computed under section 234B. 11. The ld. AO erred in not considering the extension in due for payment of the fourth instalment of advance tax and consequently, computing higher interest under section 234C . 3. It is submitted by the ld. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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