TMI Blog2015 (5) TMI 1198X X X X Extracts X X X X X X X X Extracts X X X X ..... R.P. has not passed a speaking order in this case for both the A.Ys. The assessee has raised a number of contentions before the D.R.P. and none of these contentions were considered by the D.R.P. Under these circumstances we have no other alternative but to remand the matter back to the file of the D.R.P., with a direction that D.R.P. shall pass a speaking order on each and every contention rais ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... -07 and on 27.10.2011 for the A.Y. 2007-08. As the issues arising in both the appeals are common, for the sake of convenience they are heard together and are disposed of by way of this common order. 2. Facts in brief:- Copal Research India Private Ltd. (the assessee) was incorporated in India in December, 2002. During the FY 2005-06, the assessee was engaged in provision of Information T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... relevant financial year, the assessee undertook the following international transactions with the Associated Enterprises(AEs). International Transactions for FY 2005-06 (For the AY 2006-07) Particulars Amount (in Rs.Crores) Provision of Information Technology enables Services (ITeS) 12.02 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... passed its order u/s 144C(5) of the Act. Thereafter the A.O. passed order u/s 143(3) read with section 144C of the Income Tax Act, 1961 (the Act ) for both the A.Ys. Aggrieved the assessee is in appeal before us. 4. We have heard Shri Kanchan Kaushal, CA and Shri Rohit Tiwari, CA along with Shri Anubhav Rastogi, CA, the Ld.Counsels for the assessee and Sri Judy James, Standing Counsel, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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