Principal Commissioner Of Income Tax, Delhi-2 v. Copal Research India Pvt. Ltd.

$-3 &4 In the fflGH COURT OF DELHI AT NEW DELHI ITA 187/2017. CM. APPT,.SQSQ/7ni7 PRINCIPALCOMMISSIONEROF INCOMETAX, DELHI-2 + Appellant versus COPALRESEARCHINDIAPVT. LTD.

Respondent ITA 188/2017. CM. APPT..SQQn/?ni7 PRINCIPALCOMMISSIONEROF INCOMETAX, DELHI-2 + • Appellant versus COPALRESEARCHINDIAPVT. LTD.

Respondent Through : Sh. Rahul Kaushik, Sr. Standing Counsel.

None for the respondent.

CORAM:

HON'BLEMR. JUSTICES.RAVINDRABHAT HON'BLE MR. JUSTICE NAJMIWAZIRI

ORDER

% 22.03.2017 ^ The Revenue'sgrievancein thesetwo appealsis withrespectto the order of the Income Tax Appellate Tribunal (ITAT) which doubted the use of six comparables and remitted the matter for reconsiderationof the TransferPricingOfficer(TPO). It is urged by learnedcounselthatboth the DisputeResolutionPanel(DRP) and the TPO had made reasons and sent notices as to why six comparables had to beincludedfor purposesofALP determination. The Court has considered the submissions and- also the reasoningofthe ITAT. Therecannotbe any doubtthatthe Revenueis Page I of2 By:AMULYA

not prejudiced as it is at liberty to argue all submissions which are not being foreclosed by the ITAT. In these circumstances, no substantial questionof law arises.The appealsare accordinglydismissed. iif".

S. RAVENDRA BHAT, J // NAJMl WAZmi, J MARCH 22,2017/ajk