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2020 (2) TMI 1563 - AT - Income TaxTP Adjustment - margin adopted for UK transactions and non-UK transactions - MAP proceedings of mark up - contention of the learned Authorized Representative that there is no finding by the CIT(Appeals) and non-adjudication of Map percentage on other entities - HELD THAT:- We restore the disputed issue to the file of CIT(Appeals) for fresh adjudication and findings on the margin adopted for UK transactions and non-UK transactions and pass a speaking order, and the assessee should be allowed adequate opportunity of hearing and shall cooperate in early disposal of appeal and allow the grounds of appeal of assessee for statistical purposes.
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