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2019 (1) TMI 219 - AT - Income TaxTransfer pricing adjustment relating to international taxation of the Investment Banking Division - Held that:- We find that in the first year of operation of the company, when this issue arose, which has already been set aside to the file of the AO/ TPO for fresh determination of Transfer Pricing adjustment after giving proper opportunity to the assessee. As the issue in first year has already been set aside, we in this year also, setting aside the same on similar directions to the file of the AO/ TPO. As the above issue has already been set aside for the reason that the TPO/ AP/ DRP in the absence of details furnished by assessee proceeded to apply ALP to broking transaction and we have already set aside the first issue exactly on identical reasoning’s, we restore this second issue to the file of the AO/ TPO exactly on similar directions. Hence, this issue of the assessee’s appeal is also set aside to the file of the AO /TPO.
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