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2012 (10) TMI 536 - AT - Income TaxTransfer Pricing Adjustment - arm’s length price of the international transaction entered by the appellant with its associated enterprises - Held that:- As decided in VODAFONE ESSAR LTD. versus DISPUTE RESOLUTION PANEL-II and ORS [2011 (12) TMI 22 - DELHI HIGH COURT] when a quasi judicial authority like the DRP deals with a lis u/s 144C, then, it is obligatory on its part to give cogent reasons for the decision. DRP has passed its order by just relying on the findings recorded by the A.O./TPO, without considering the various objections raised before it by the assessee. A perusal of the DRP order shows that it is a short order passed in general terms on both the issues involved, i.e., arm’s length price u/s 92CA(3) and excess depreciation on computer accessories and peripherals. The objections raised by the assessee before the ld. DRP have not been discussed in detail - Remit this matter to the file of the DRP, to be decided afresh in accordance with the law by passing a speaking order on affording adequate and proper opportunity of hearing to the assessee
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