Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2015 (5) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2015 (5) TMI 465 - AT - Income TaxDetermination of Arm's length price - Method of determining the price - Non consideration of issues - Held that:- Grievance of the assessee is limited to the fact that submissions made before DRP on 29/08/11 on the merits of various issues raised against the determination of ALP by TPO has not at all been considered by DRP. On a perusal of the material on record, we find that though the DRP has considered part of the written submissions filed by assessee, which has been incorporated in the order of DRP, but, the submissions made by assessee on merits which were claimed to have been filed before DRP on 29/08/11 have not at all been considered. Furthermore, assessee’s grievance that the TPO without giving assessee opportunity has changed PLI from operating profit to sales to operating profit to cost also needs to be addressed by DRP - Matter remanded back - Decided in favour of assessee.
|