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2021 (2) TMI 579 - AT - Income TaxTP Adjustment - aggregate figure to be adopted between the assessee and its overseas associate enterprise(s) pertaining to the international transactions in the nature of container line income/container line expenses, reimbursement of expenses paid, liner agency services, slot hire income & slot expenses disclosed in Form 3-CEB report - HELD THAT:- We notice that neither the TPO's order dated 29.01.2015 nor the DRP's above extracted directions under challenge have specified as to whether they have adopted cost/revenues of the international transactions in issue only or that of the entire activities involving the twin entities' gross transactions. We quote CIT Vs. Firestone International [P.] Ltd. [2015 (6) TMI 1123 - BOMBAY HIGH COURT] and restore the instant issue of the correct arm's length price of the assessee's international transactions with its "A.Es." which deserves to be adjudicated afresh keeping in mind the said international transactions between them only. It is made abundantly clear before parting that there is no other dispute between the parties regarding the method adopted as well the book results before us. As already indicated in the preceding paragraph, the clinching issue of the entity level or International transaction level's gross receipts/incomes pertaining to this issue still stands unresolved. We thus reiterate our foregoing directions and restore the Revenue's sole substantive grievance back to the TPO for his fresh adjudication to this limited extent. It shall be open for the assessee to place on record all the relevant data in consequential proceedings to be concluded within three effective opportunities of hearing.
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