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2011 (9) TMI 296 - AT - Income TaxArm length price - whether cost plus method, as claimed by the assessee and as applied by the assessee, is sustainable in law - Noted that the assessee was duly confronted with comparable cases for application of transaction net margin method, but the assessee did not have anything to say beyond his rather vague and generalized objections to the application of TNMM and insistence that the CUP and CPM method adopted by him should not be disturbed - Even in proceedings, no specific submissions have been made in this regard, nor any document, in support of his stand on comparable cases being incorrect, have been filed in the paper-book - There is no discussion whatsoever about precise comparability of the cases selected for TNMM, nor is there any application of suitable filters, even if any - Therefore, it deem fit and proper to remit the matter to the file of the CIT(A) for adjudication de novo in the light of our above observations and in the light of whatever additional material the assessee is able to produce in support of his grievances, in accordance with the law, by way of a speaking order and after giving a reasonable opportunity of hearing to the assessee.
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