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TMI Blog2016 (5) TMI 1621X X X X Extracts X X X X X X X X Extracts X X X X ..... of assessee that fixed deposits are to be maintained with bank for the requirement of LC - case of the Assessee is that it has placed its unutilized funds in short term fixed deposits with banks which is yielding interest income. HELD THAT:- In the grounds of appeal before the ITAT no specific challenge was raised by the Assessee to the above factual finding that the FDs were not being maintained ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... has remitted the matter to the Assessing Officer ( AO)/ Transfer Pricing Officer ( TPO ) for a fresh determination of the issue. 2. Mr. Deepak Chopra, learned counsel for the Appellant Assessee states that ITAT ought to have referred to a chart submitted by the Assessee listing out the comparables that were required to be included and those that were required to be excluded. Mr. Asheesh Jain, lea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ary 2015, which reads thus : 11. As. Regards the questions of comparables, we have noted that the benefit of detailed analysis by the coordinate benches, which has been relied upon by the assessee, was not before the authorities below. The detailed factual contentions, as made before us, are necessarily required to be dealt with by way of a speaking order, rather than on the basis of vague general ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... m fixed deposit as income from other sources and not business income as has been contended by the Assessee, the Court finds that Dispute Resolution Panel ( DRP ) in para 15.3 of its order dated 20th December 2013, observed that It is also not the case of assessee that fixed deposits are to be maintained with bank for the requirement of LC . The case of the Assessee is that it has placed its unutil ..... X X X X Extracts X X X X X X X X Extracts X X X X
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