TMI Blog2017 (7) TMI 1346X X X X Extracts X X X X X X X X Extracts X X X X ..... Sony Ericson Mobile Communications (India) Pvt. Ltd. v. CIT [ 2015 (3) TMI 580 - DELHI HIGH COURT] and also some of the subsequent judgments where the Court has held that in matters of transfer pricing the first exercise that is to be undertaken is to determine if in fact there existed an international transaction between the Assessee at its Associated Enterprise. Only if the said question is ans ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reasons as stated in the application, the delay in filing is condoned. The application stands disposed of. CM No.25168/2017 (exemption) in ITA No.524/2017 2. Allowed, subject to all just exceptions. ITA No.524/2017 and ITA No.432/2017 3. These appeals by the Revenue and Assessee are directed against the same order dated 22nd November, 2016 passed by th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion between the Assessee at its Associated Enterprise. Only if the said question is answered in the affirmative, the further question of determining its arm s length price would arise. Counsel on both sides state that all the necessary documents and information for determining the above question already form part of the record of the case in the ITAT. 5. In view of the above submissions ..... X X X X Extracts X X X X X X X X Extracts X X X X
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