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2012 (11) TMI 800 - AT - Income TaxMatter referring to TPO u/s 92CA – Opportunity to the assessee – Whether opportunity to assessee has to be given before referring matter for computation of arm's length price to the TPO – Held that:- There is no specific provisions for giving any opportunity to the assessee before reference to the TPO. It is for the AO when he considers it necessary or expedient so to do, he may refer the computation of arm's length price in relation to the said international transaction u/s 92C to the Transfer Pricing Officer. Issue decides in favour of revenue Disallowance of foreign travel expenditure – Held that:- Since the AO has not given any reason for disallowance of such expenses. What has been done by the AO is that he made a disallowance in the computational part without assigning any reason. Therefore, in the facts and circumstances of the case, disallowance made by the AO is not justified. Issue decides in favour of assessee
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