Domestic
Company cannot be compared with the taxpayer who is mainly
an exporter.
(e) In the case of Mis Ranbxy India ... comparable when the taxpayer is mainly an exporter.
(6) By considering the export earnings criterion, an attempt has
been made by TPO to taken into
loan and that the AO nor the CIT(A) , made any attempt to independently verify the
4
ITA No. 1570/Del/2013
Raj Hans Towers ... addition. He relied on the
following case laws :-
a) CIT vs. Metaphor Exports P. Ltd. (dated 13.1.2015)
b) ITO vs. Rakam Money Matters
done in the name of M/s Fortune a Baddi,
Himachal Pradesh. Export is carried out in the name of M/s Da
Milano, Gulmohar ... Total sales to these parties
ran into several crores of rupees. No attempt had been made by the
AO to verify whether the sales were
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