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2019 (9) TMI 386 - AT - Income TaxTP Addition - HELD THAT:- As perused all decisions passed by this Tribunal in assessee’s own case for assessment years 2005-06 to 2013-14 and found that issues in present appeal are common with earlier years and have been set aside to TPO on the ground that TPO as well as DRP failed to consider objections raised by assessee. Transfer pricing addition made by Ld.AO. It is observed that DRP/TPO for year under consideration did not consider objections raised by assessee against comparables selected by Ld.TPO and simply followed DRP directions issued for AY 2013-14. As AY: 2013-14 has been set aside by this Tribunal, we deem it fit and proper to remit the issues to file of AO/TPO for taking necessary action of passing a speaking order by granting fair opportunity to assessee of being heard. It is also observed that all these issues are pending before lower authorities and we find no reason to adjudicate these issues at this stage. Accordingly, following earlier orders passed by this Tribunal in assessee’s own case, we set aside all issues to Ld.AO for re-adjudication of issues in the light of the findings given in earlier years - Appeal filed by assessee stands allowed for statistical purposes.
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