2021 (9) TMI 1545

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..... Ware Limited by the Transfer Pricing Officer (TPO) - HELD THAT:- DR fails to dispute that the DRP herein has nowhere taken into consideration the assessee's detailed objections quoting functional similarity, lack of the relevant segmental financials and engagement of the said twin entities in R D activities, whilst declining the impugned objection in a cryptic manner. Faced with this situation .....

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..... r.w.s. 144C(13) of the Income Tax Act, 1961 ('the Act'). Heard both the parties. Case file perused. 2. The assessee raises the following substantive grounds in the instant appeal : 3. Learned counsel submits at the outset that the assessee restricted his pleadings only qua wrongful inclusion of two comparables M/s. HSIL Ltd and M/s. Cera Sanitary Ware Limited by the Transfer Pricing Offic .....

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..... company as functionally comparable, referring to the annual report of this company. We note that the assessee has not controverted the factual findings of the TPO. Therefore we upheld the selection of this comparable. 4. Learned department representative fails to dispute that the DRP herein has nowhere taken into consideration the assessee's detailed objections quoting functional similarity, l .....

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