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2018 (6) TMI 1396 - HC - Income TaxAdditions made under ALP pricing provisions - additions u/s 40[a][ia] - Held that:- We are of the opinion that since both the issues with regard to TP adjustments under Section 92CA of the Act as well as disallowances under Section 40[a][ia] of the Act, the matter is remanded back by the learned Tribunal to the Assessing Officer, the observations made by the learned Tribunal in Paragraph-26 will depend upon the findings of facts which are arrived at again by the Assessing Officer upon such remand by Tribunal. We consider it appropriate to leave the said question of law open for consideration after appropriate orders are passed upon fresh enquiry by the learned Assessing Officer, upon such remand by Tribunal.
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