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TMI Blog2019 (8) TMI 22X X X X Extracts X X X X X X X X Extracts X X X X ..... the issue whether there is at all an international transaction involving the Assessee and its Associated Enterprise ( AE )? - HELD THAT:- The facts of the present case need not be discussed in great detail because essentially, what the ITAT has done is to remand the matter to the TPO, and this by itself does not give rise to any substantial question of law. ITAT has noted that the Assessee is inc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... -2019 - S. MURALIDHAR AND TALWANT SINGH JJ. Appellant Through: Ms. Vibhooti Malhotra, Senior Standing Counsel with Mr. Shailendra Singh, Advocate Respondent Through: None O R D E R CM APPL. 33399/2019 (Exemption) 1. Allowed, subject to all just exceptions. CM APPL. 33400/2019 (delay in re-filing the appeal) 2. For t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nternational transaction is required to be determined? 5. The facts of the present case need not be discussed in great detail because essentially, what the ITAT has done is to remand the matter to the TPO, and this by itself does not give rise to any substantial question of law. The ITAT has noted that the Assessee is incurring its own selling and distribution expenses and there was no ad ..... X X X X Extracts X X X X X X X X Extracts X X X X
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