cited the following Tribunal decisions in support of his contention :
1. Raymond Woollen Mills Ltd. v. IT0 (1996) 57 ITD 536 (Bom);
2. Sheraton International ... assessee. He submitted, with respect that the decision rendered in Raymond Woollen Mills Ltd. v. IT0 (1996) 57 ITD 536 (Bom.) and subsequent Tribunal decisions
Income
Tax Appellate Tribunal ("Tribunal") in the case of
Raymond Ltd. vs. Dy. CIT (2 003) 86 ITD 791
(Mumbai). The Tribunal, after ... without recourse to
the performer of services, in future". In Raymond's
case (supra) , the Tribunal also hel d that rendering of
technical
Decision of the Hon'ble Supreme Court in the case of Raymond
Woollen Mills Ltd. (1999) 236 ITR 34 (SC)
3.2.2 The learned Senior ... High Court analyzed the
decisions in the cases of Raymond Woollen Mills Ltd. vs. ITO & Ors .
19
ITA No. 1791/Del/2013
Retail Ltd. TPO 44.47%
13 V-mart Retail Ltd. TPO 47.54%
14 Raymond Apparel Ltd. TPO 71.48%
15 Tengerine Design Pvt. TPO 71.54%
Ltd.
Median ... 4348/Del/2024
Louis Vuitton India Retail Pvt. Ltd. Vs. DCIT
11. Raymond Apparel Limited
This company has been held to be suitable
decision of Hon'ble
ITAT, Bombay in the case of Raymond Ltd. and
also the decision of Kolkata High Court in the case ... Counsel for the assessee has relied upon the
following decisions: -
i) Raymond Ltd. Vs. DCIT 86 ITD 791 (Mum.)
ii) Real Resourcing
comparable companies.
4.2. The Hon'ble DRP/TPO erred in accepting Raymond
Apparel Limited which has significant related party
transactions, as comparable company ... follows:
S. Name of the company OP/Sales OP/OC
No.
1. Raymond Apparel Limited 12.14% 12.99%
2. Arvind Brands Limited
Skycell Communications Ltd. Vs. DCIT (119 Taxman 496) (Madras);
Raymond ltd. vs.DCIT,86 ITD 791(Mumbai);Pan AmSat International Systems
Inc.,103 TTJ861;CESC ... Income Tax Act. We also find
that the case law of Raymond Limited relied upon by the assessee
in fact supports the contention
Bombay High
Court in the case of CIT vs. Raymond Ltd. (IT Appeal No. 188 of 2011),
wherein the assessee had issued non-convertible debentures ... made by the AO relying on the case of CIT
Vs Raymond Ltd. ITA 188/2011 (Bom.) holding that-
"The principle which has been
order of Hon'ble ITAT in the case of Raymond Woolen Mills Ltd. v. ITO , in which it was held that the period ... question. It was his case that the order in the case of Raymond Woolen Mills Ltd. (supra) was passed after considering a number of authorities
following observations of the Third Member in the case of Raymond Woollen Mills Ltd. v. ITO [1986] 18 ITD 64 (Bom) to come ... facts ;
(m) That the decision of the Tribunal in the case of Raymond Woollen Mills
