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2018 (10) TMI 1502 - AT - Income TaxTPA - Arm's length price adjustment - international transactions of sale/resale of manufactured goods in export, payments of sales margins, services rendered etc. to its associate enterprises - admission of additional evidence - Held that:- The fact remains that the TPO is already seized of the very issue is earlier assessment years 2011-12 & 2012-13. This consequential adjudication would indeed carry all ramifications in the impugned assessment year as well. We adopt judicial consistency in these peculiar facts and circumstances to restore the impugned ALP adjustment issue back to the TPO for his simultaneous adjudication in all these assessment years. The Revenue's argument strongly supporting the impugned adjustment are rejected to this limited extent at this stage. - Decided in favour of assessee for statistical purposes.
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