case for Assessment
Year 2011-12 has upheld the export filter of 10%, therefore, Clutch
Auto should also be rejected as the same is having ... Thus, export sales are 11.42% to total sales,
thus submitted that the said company deserves to be rejected due
to the export turnover filter
case for Assessment
Year 2011-12 has upheld the export filter of 10%, therefore, Clutch
Auto should also be rejected as the same is having ... Thus, export sales are 11.42% to total sales,
thus submitted that the said company deserves to be rejected due
to the export turnover filter
case for Assessment
Year 2011-12 has upheld the export filter of 10%, therefore, Clutch
Auto should also be rejected as the same is having ... Thus, export sales are 11.42% to total sales,
thus submitted that the said company deserves to be rejected due
to the export turnover filter
company should have
substantial export activity as the assessee before us is 100%
EOU. With such understanding, the export filter should not
be kept ... selected having
substantial export.
11.4.4 Therefore, the submission of the assessee to consider
the export turnover filter at 25% as done in TP study
Asst.Years -2009-10 & 2010-11
-2-
have relaxed the export filter to 25% and based on the same, arrived at a single
comparable ... first
round of litigation, took the export filter at 50% and again took GTN as the
single / sole comparable and accordingly, conducted a fresh benchmarking
Asst.Years -2009-10 & 2010-11
-2-
have relaxed the export filter to 25% and based on the same, arrived at a single
comparable ... first
round of litigation, took the export filter at 50% and again took GTN as the
single / sole comparable and accordingly, conducted a fresh benchmarking
export turnover exceeds the domestic turnover and,
therefore, this cannot be treated as a comparable. TPO had not applied the
export filter while choosing this ... other hand the export to turnover ratio of the assesse company was only
4.72%. As this issue of export filter was neither raised before
filter.
iii. Improper application of the employees cost filter.
10.1 Subsequently, the TPO conducted a fresh search for comparable
companies using the following filters:
- Companies ... onwards)
6. The Id. A.R. submitted that Datamatics fails the export filter applied by
the learned TPO, lacks segmental data and therefore, should
those having the character of heat-insulating
goods of heading 68.06.
(9) Filter tubes of finely crushed and agglomerated quartz or flint.
(10) Blocks, slabs ... untenable, since handicraft articles
sculpted out of stone and of the kind exported by the petitioner cannot
possibly be countenanced as answering to the description
those having the character of heat-insulating
goods of heading 68.06.
(9) Filter tubes of finely crushed and agglomerated quartz or flint.
(10) Blocks, slabs ... untenable, since handicraft articles
sculpted out of stone and of the kind exported by the petitioner cannot
possibly be countenanced as answering to the description
