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2011 (4) TMI 124 - AT - Income TaxArm's length price - Rectification of mistakes - the financial data of these 3 companies of the current relevant year were not in public domain at the time when the TPO passed the order, is not in dispute - Under Rule 29 of the Income-tax Appellate Tribunal Rules, the Tribunal has the power to allow additional evidence, not only if it requires such evidence to enable it to pronounce judgment but also for any other substantial cause - since the additional evidences so produced by the revenue with regard to the issue relating to PE, the matter was necessary to be restored to the file of the Assessing Officer for deciding the same afresh after examining the additional evidence as well as explanation offered by the assessee while rebutting the same Regarding determination of arm's length price - Since this issue is also closely connected to the main issue regarding determination of arm's length price - Decided in the favour of the assessee by way of remand
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