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2014 (12) TMI 1158 - AT - Income TaxTransfer pricing adjustment - Royalty payment was at arm's length which cover a substantial part of TPO's disallowance at ₹ 156,43,832/- - Held that:- We find that the TPO has made the elaborate order whereby he has only dealt with royalty aspect and not dealt with the other allied payments. The royalty payment has been allowed by the DRP. In these circumstances, assessee will be put to great hardship, if the TPO is given a second inning to make out a fresh case. Hence, we reject these submissions made by the Ld. Departmental Representative. - Decided in favour of assessee. Reimbursement of expenses disallowed - Held that:- Interest of justice demands that’s the matt4er may be remitted to the file of the A.O. Accordingly, this issue is remitted back to the file of the A.O. A.O. is directed to examine in detail the details and break-up in the time charts submitted by the assessee and thereafter consider the issue afresh - Decided in favour of assessee for statistical purposes.
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