2024 (12) TMI 645

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..... ed the second round of litigation since in the first round of proceedings before it, the appeal was disposed of and the matter remanded back to the TPO - HELD THAT:- Tribunal has taken into consideration the undisputed fact that by the time this appeal came to be taken up for consideration, the Department had taken a consistent view in AY 2007-08 to 2011- 12 insofar as comparables and controlled t .....

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..... T VARMA AND HON'BLE MR. JUSTICE RAVINDER DUDEJA For the Petitioner: Mr. Shlok Chandra, SSC with Ms. Madhavi Shukla, Ms. Priya Sarkar, JSCs, Mr. Sudarshan Roy Ms. Kavita Rani, Advs For the Respondent: Mr. Neeraj Jain Mr. Aniket D. Agrawal, Advs ORDER 1. The Principal Commissioner seeks to assail the order of the Income Tax Appellate Tribunal [ Tribunal ] dated 31 July 2017 and which has been re .....

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..... s after allocating respective revenues and expenses to both the segmental. The Assessing officer/ TPO shall provide reasonable opportunity of being heard to the assessee. The assessee shall furnish all the details and particulars before the authorities below to enable them to make internal comparison of the profitability from the international transactions with associated enterprise and unrelated .....

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