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2015 (6) TMI 927 - AT - Income TaxTransfer pricing adjustment - TPO rejected the internal bench marking carried out by the assessee since the segmentation of its accounts was artificially created by the assessee for the purpose of transfer pricing - TPO has taken OP/Sales as Profit Level Indicator (PLI) and taken the segmental of the comparable companies wherever it was available - Held that:- Order dated 30.4.2010 passed by the Dispute Resolution Panel (DRP), New Delhi u/s. 144C of the I.T. Act, 1961 is a cryptic and non speaking one. None of the contentions raised by the assessee, have been dealt with by the DRP. Under the circumstances, we have no other alternative, but to remand back the matter to the file of the DRP for fresh adjudication, in accordance with law. The DRP shall pass a speaking order and address all the contentions raised by the assessee.- Decided in fvaour of assessee for statistical purposes.
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