Arithmetic mean over weighted average mean
DCIT vs Ankit Metal & Power Ltd; Income Tax Appellate Tribunal Kolkata The assessee company was engaged in the business of manufacturing Ferro-alloys, Ingots, trading in TMT Bar and selling beneficiation coal. For AY 2013-14, being the year under appeal, the assessee company has filed its Return of Income on 30.11.2013 declaring a total loss of Rs. 13.70 crores. The assessee paid tax on book profit u/s 115JB at Rs.13.7 crores. The Assessee’s case was selected for scrutiny through CASS and statutory notices were served upon the assessee to which the assessee responded with the requisite explanation/documents. Thereafter, the AO referred the domestic specific transaction with the related parties to TPO. SDT transaction involving the purchase of raw materials for sister concern/ AE TPO noted that the assessee had purchased several raw materials from its related parties. The assessee had benchmarked these purchases applying the Comparable Uncontrolled Price Method (‘CUP’ Method). The a...