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2013 (9) TMI 236 - AT - Income TaxDisallowance of Revenue expenditure - Business not set up - Transfer pricing - ALP - Reasons for decision - Held that:- it is obligatory, for the DRP on its part to ascribe cogent and germane reasons for arriving at a conclusion. The reasons are heart and soul of the matter and they facilitate appreciation when the order is called in question before a Superior forum or an appellate forum. Since the detailed findings supported by the reasons of the DRP are not before us it would not be appropriate to considers the grounds raised by the assessee before us and it is necessary to hold that the matter deserves to be remitted back to the DRP for proper adjudication on all the objections in the grounds raised by the assessee. Needless to say, that the DRP after affording reasonable opportunity of being heard to both the parties shall deliver a speaking order as per the requirements of law and procedure accepted by the Courts - Decided in favour of assessee.
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