Analysis

Assessm Type Of Issues

In
ent year Appeal Dealt whose
With favour
Valid

107

115

115

115

Missing

Mean

7.24

1.08

6.72

1.60

Median

7.00

1.00

8.00

1.00

Mode

Std. Deviation

1.868

.328

3.257

1.066

Variance

3.488

.108

10.606

1.137

Sum

775

124

773

184

Assessment year
Frequency

Valid

2002-03

.9

.9

Cumulative
Percent
.9

2003-04

1.7

1.9

2.8

2004-05

6.1

6.5

9.3

2005-06

6.1

6.5

15.9

2006-07

19

16.5

17.8

33.6

2007-08

23

20.0

21.5

55.1

2008-09

16

13.9

15.0

70.1

2009-10

19

16.5

17.8

87.9

2010-11

13

11.3

12.1

100.0

107

93.0

100.0

7.0

115

100.0

Total

Missing
Total

System

Percent

Valid
Percent

Total No. of Valid cases for Analysis =107

1. In 2002-03 ,1 case was registered. It is only 0.9% of the

total cases.
2. In 2003-04 ,2 cases were registered. It is only 1.9% of the
total cases.
3. In 2004-05 ,7 cases were registered. It is only 6.5% of the
total cases.
4. In 2005-06 ,7 cases were registered. It is only 6.5% of the
total cases.
5. In 2006-07 ,19 cases were registered. It is only 17.8% of
the total cases.
6. In 2007-08 ,23 cases were registered. It is only 21.5% of
the total cases.
7. In 2008-09 ,16 cases were registered. It is only 15% of the
total cases.
8. In 2009-10 ,19 cases were registered. It is only 17.8% of
the total cases.
9. In 2010-11 ,13 cases were registered. It is only 12.1% of
the total cases.

Histogram

Type Of Appeal

Frequency

Valid

Percent

Valid Percent Cumulative

Percent
93.9
93.9
93.9

Regular Appeal

108

Stay Application

4.3

4.3

98.3

Miscellaneous
Application

1.7

1.7

100.0

115

100.0

100.0

Total

There are total 115 Appeals and there are 3 types of appeals
1. There are total 108 Regular Appeal, 93.9% of total appeals.
2. There are total 5 Stay Application, 4.3% of total appeals.
3. There are total 2 Miscellaneous Application, 1.7% of total appeals.

Issues Dealt With

Frequency Percent

Valid

Cumulative
Percent

Applicability of chapter X provisions

.9

.9

.9

Disputes arising out of the transfer Pricing

assessment proceedings

13

11.3

11.3

12.2

Disputes pertaining to arm's length price

computation under Section 92C and 92F
r.w.r 10B

12

10.4

10.4

22.6

Disputes pertaining to benchmarking and

comparability

16

13.9

13.9

36.5

Disputes pertaining to Dispute Resolution

Panel proceedings

4.3

4.3

40.9

Disputes pertaining to economic

adjustments conducted in benchmarking

1.7

1.7

42.6

Disputes pertaining to filters applied under

benchmarking

7.0

7.0

49.6

Disputes pertaining to functional

classification of Assessee and comparables

23

20.0

20.0

69.6

Disputes pertaining to Income Tax Appellate

Tribunal proceedings

2.6

2.6

72.2

Disputes pertaining to International

transactions under Section 92B

20

17.4

17.4

89.6

Disputes pertaining to interpretation of

definitions under the Act

2.6

2.6

92.2

Disputes pertaining to methods prescribed

under Section 92C r.w.r 10B

7.0

7.0

99.1

Disputes pertaining to penalties imposed by

AO

.9

.9

100.0

115

100.0

100.0

Total

Valid
Percent

There are total no. of 115 cases and 13 issues.

1.

There is only 1 case in which the issue was releated to Applicability

of chapter X provisions and it is 0.9% of the total cases.

2. There are 13 cases in which the issue was releated to Disputes arising
out of the transfer Pricing assessment proceedings and it is 11.3% of
the total cases.
3. There are 12 cases in which the issue was releated to Disputes
pertaining to arm's length price computation under Section 92C and
92F r.w.r 10B and it is 10.4% of the total cases.
4. There are 16 cases in which the issue was releated to Disputes
pertaining to benchmarking and comparability and it is 13.9% of the
total cases.
5. There are 5 cases in which the issue was releated to Disputes
pertaining to Dispute Resolution Panel proceedings and it is 4.3% of
total cases.
6. There are 2 cases in which the issue was releated to Disputes
pertaining to economic adjustments conducted in benchmarking and it
is 1.7% of total cases.
7. There are 8 cases in which the issue was releated to Disputes
pertaining to filters applied under benchmarking and it is 7% of total
cases.
8. There 23 cases in which the issue was releated to Disputes pertaining
to functional classification of Assessee and comparables and it is 20%
of total cases.

9. There 3 cases in which the issue was releated to Disputes pertaining

to Income Tax Appellate Tribunal proceedings and it is 2.6% of total
cases.
10. There are 20 cases in the issue was releated to Disputes pertaining
to International transactions under Section 92B and it is 17.4% of
total cases.
11. There are 3 cases in which the issue was releated to Disputes
pertaining to interpretation of definitions under the Act and it is 2.6%
of total cases.
12. There are 8 cases in which the issue was releated to Disputes
pertaining to methods prescribed under Section 92C r.w.r 10B and it
is 7.0% of total cases.
13. There is only 1 case in which the issue was releated to Disputes
pertaining to penalties imposed by AO and it is 0.9% of total cases.

Histogram

In Whose Favour

Valid

Frequency

Percent
67.0

Valid
Percent
67.0

Cumulative
Percent
67.0

Assessee

77

Partly allowed Assessee

22

19.1

19.1

86.1

Revenue

5.2

5.2

91.3

Partly allowed Revenue

4.3

4.3

95.7

Partly allowed - Assessee, Partly

allowed Revenue

4.3

4.3

100.0

Total

115

100.0

100.0

There are 115 appeals and an appeal can result only 1 out
of these 5.

1. There are 77 cases in which the case is declared in Favour of

Assessee, 67% of total appeals.
2. There are 22 cases in which the appeal of assessee is partly allowed,
19.1% of total appeals.
3. There are 6 cases in which the case is declared in favour of Revenue,
5.2% of total appeals.
4. There are 5 cases in which the appeal is partly declared in faovour of
revenue, 4.3% of total appeals.
5. There are 5 cases in which the appeal is partly allowed in favour of
assessee as well as revenue, 4.3% of total appeals.

Histogram