TPO not justified in rejecting computation of ALP made by assessee by applying CUP method if all comparables are fairly unrelated

IN THE ITAT HYDERABAD BENCH ‘A’ Assistant Commissioner of Income-tax Versus Ckar Systems (P) Ltd. IT Appeal No. 565 (Hyd.) of 2011 [Assessment year 2005-06] OCTOBER 19, 2012 ORDER Saktijit Dey, Judicial Member This appeal by the Revenue is directed against the order of the CIT(A) III, Hyderabad dated 28.1.2011, for the assessment year 2005-06. 2. The Department has raised the following grounds- “1. The order of the CIT(A) is erroneous on the facts and in the circumstances of the case.  2. The Ld. CIT(A) ought to have upheld the addition of Rs. 1,70,51,255 m...