Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2022 (9) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2022 (9) TMI 453 - AT - Income TaxTP Adjustment - Analysing the international transaction - services rendered by assessee to be ITES by the Ld. TPO, as against back office support services carried considered by assessee - HELD THAT:- We note that analysing the international transaction based on wrong assumption of the services rendered would prejudice the computation of arms length. In the interest of justice, we remand the entire computation of arms length to the Ld. TPO for denovo assessment. Needless to say that proper opportunity of being heard must be granted to assessee in accordance with law. Accordingly, the grounds raised by assessee stands allowed for statistical purposes.
|