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2014 (4) TMI 1277 - AT - Income TaxTaxability and the extent qua the income from off-shore supply of equipments; income from on-shore equipments; income from on-shore services; and income from design and engineering services - Transfer Pricing Adjustment - HELD THAT:- Such issues have been sent back by the tribunal to the AO/TPO for a fresh decision in accordance with the specific directions given therein. Since both the sides are in agreement that the facts and circumstances as well as the grounds of the extant appeal are mutatis mutandis similar to those for A.Y. 2008-09, following the precedent we set aside the impugned order and remit the matter to the file of AO/TPO for deciding these issues afresh in conformity with the directions by the Tribunal in its order for A.Y. 2008-09 [2014 (3) TMI 368 - ITAT DELHI].
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