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2012 (10) TMI 206 - AT - Income TaxTransfer pricing adjustments - ALP - AO while framing the assessment did not carry out the directions of the DRP in this behalf. - held that:- AO has not carried out the rectification order passed by TPO and passed the assessment order without carrying out the DRP directions. - the issue of assessee being a non-risk bearing agent has to be looked into along with the suitability comparables. - matter remanded back to AO to reconsider the issue of transfer pricing in accordance with law after giving the assessee an opportunity of being heard. - at the time of dictation of this order, the issue of 92C [(+) (-)] adjustment is proposed to be amended which shall be kept in mind.
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