2018 (11) TMI 1697

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..... aforesaid question, the respondent-assessee would be entitled to raise the issue and question that the Assessing Officer had disallowed the entire expenditure on royalty etc. without referring to any comparables by applying benefit test. Accordingly, the Tribunal should not have remanded the matter to the Assessing Officer. Filing of printed paper book is dispensed with. However, parties are .....

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..... and independent international transactions which were required to be benchmarked separately by applying the Comparable Uncontrolled Price Method? While examining the aforesaid question, the respondent-assessee would be entitled to raise the issue and question that the Assessing Officer had disallowed the entire expenditure on royalty etc. without referring to any comparables by applying .....

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