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TMI Blog2024 (6) TMI 466X X X X Extracts X X X X X X X X Extracts X X X X ..... Net Margin Method (TNMM) as the most appropriate method while TPO applied RPM - HELD THAT:- DRP vide directions granted part relief to the assessee. The Assessing Officer passed the impugned order in accordance with the directions of the DRP. No material to controvert the findings of the Assessing Officer or the order of Transfer Pricing Officer is furnished before the Tribunal. Thus, we uphold th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eal was adjourned to 01.05.2019 at the request of ld. DR. Thereafter on 01.05.2019 the assessee sought adjournment to file paper book. The assessee again on 17.09.2019 sought adjournment. The Bench vacated the benefit of early hearing allowed to the assessee. The appeal was thereafter adjourned to 14.11.2019. On the said date bench did not function and the appeal was adjourned to 22.01.2020. On 22 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 022, 28.02.2023, 11.05.2023, 17.08.2023, 23.11.2023 and 22.02.2024. The notices were sent to the assessee on various dates through RPAD. The notices were received back unserved from the postal authorities with remarks, closed since long/left. The notices were sent to the assessee on the address furnished in Form no. 36. The assessee has not furnished any revised Form No. 36 intimating its current/ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f energy, industry, transport, service, communication etc. During the period relevant to assessment year under appeal, the assessee entered into various international transactions. To benchmark the Arm s Length Price (ALP) of the transactions, the assessee applied Transactional Net Margin Method (TNMM) as the most appropriate method. The TPO vide order dated 26.10.2017 rejected TNMM in trading seg ..... X X X X Extracts X X X X X X X X Extracts X X X X
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