While Computing ALP with CUP method TPO cannot ignore negative deviations

ITAT CHENNAI Mainetti India (P.) Ltd. v/s.  ACIT IT APPEAL NO. 1789 (MDS.) OF 2011 [ASSESSMENT YEAR 2007-08] MARCH 16, 2012 ORDER George Mathan, Judicial Member – This appeal is filed by the assessee against the assessment order dated 27.09.2011 and also the order of the Dispute Resolution Panel (DRP) Chennai in F.No.DRP/Chennai/Sectt./016/2011-12 dated 19.08.2011 for the Assessment Year 2007-08. 2. In this appeal, the assessee has raised the following grounds:- “1.  For that the order of the Assessing Officer is contrary to law, facts and circumstances of the c...