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7.2 Without prejudice, the TPO/DCIT, ought to have accepted the appellant's revised bench-marking result furnished during the assessment proceedings which also satisfied ALP.

9.1 During the course of assessment proceedings, the appellant vide its letter dated 18-09-2007 & 07-10-2008 719((TP)A2011 & ITA No.1211(B)/15 submitted that it was engaged in providing basic design and application development services which was in the field of Research &Development in the Automotive Manufacturing Industry i.e. starter motors and alternators, which was its main business. The appellant requested the AO to adopt seven comparables selected by it based on the financials of FY: 2004-05, which is reproduced below;