TMI Blog2019 (2) TMI 820X X X X Extracts X X X X X X X X Extracts X X X X ..... This even though it had remanded the issue of determining the ALP of the transactions to the AO/ TPO. Mr. Thakkar points out that on remand, the Assessing Officer passed an order even examining the issue of transaction being an international transaction or not. This order of the AO (on remand) is now in the appeal before the Tribunal. Thus, the issue raised herein viz. whether the transaction is i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y the Tribunal. - INCOME TAX APPEAL NO. 1404 OF 2016 - - - Dated:- 6-2-2019 - AKIL KURESHI M.S. SANKLECHA, JJ. Mr. Nishant Thakkar a/w Mr. Hiten Chande i/by PDS Legal for the Appellant Mr. Arvind Pinto for the Respondent P.C.: 1. This appeal under Section 260A of the Income Tax Act, 1961 ( the Act for short), challenges the order dated 31.12.2015 passed by the Income T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... / Transfer Pricing Officer. Mr. Thakkar points out that on remand, the Assessing Officer passed an order even examining the issue of transaction being an international transaction or not. This order of the Assessing Officer (on remand) is now in the appeal before the Tribunal. Thus, the issue raised herein viz. whether the transaction is international transaction or not for the purpose of determi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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