ITAT Delhi: Comparable Cannot Be Rejected When Functions Remain Unchanged

Sanden Vikas India Pvt. Ltd Vs ACIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT) considered the appeal filed by Sanden Vikas India Pvt. Ltd. against the assessment order passed under Sections 143(3), 144C(13), and 144B of the Income Tax Act, 1961, pursuant to the directions of the Dispute Resolution Panel (DRP). The assessee had also raised an additional ground challenging the validity of the assessment as being barred by limitation in light of a Madras High Court decision. However, this additional ground was subsequently withdrawn and was therefore not admitted. The assessee challeng...