TMI Blog2020 (2) TMI 1563X X X X Extracts X X X X X X X X Extracts X X X X ..... tage on other entities - HELD THAT:- We restore the disputed issue to the file of CIT(Appeals) for fresh adjudication and findings on the margin adopted for UK transactions and non-UK transactions and pass a speaking order, and the assessee should be allowed adequate opportunity of hearing and shall cooperate in early disposal of appeal and allow the grounds of appeal of assessee for statistical p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... I Scheme and filed the Return of Income for the Assessment Year 2008-09 on 29.09.2008 with total income of ₹ 87,81,038. Subsequently, the case was selected for scrutiny and Notice under Section 143(2) of the Act was issued. In compliance, the learned Authorized Representative of the assessee appeared from time to time and submitted the details. The Assessing Officer found that assessee has i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Pricing Adjustments under Section 92CA of ₹ 320,581,011 and disallowance under Section 40a(ia) of the Act of ₹ 364,157. Aggrieved by the order, the assessee has filed an appeal with the CIT(Appeals). Whereas the CIT(Appeals) considering the submissions on the MAP proceedings of mark up has observed at paras 5.1 and 5.2 as under : Finally, the CIT(Appeals) has partly allowed the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l on record. Prima facie, the contention of the learned Authorized Representative that there is no finding by the CIT(Appeals) and non-adjudication of Map percentage on other entities. We find the co-ordinate bench of the Tribunal in the case of DCIT Vs. Global e-Business (supra) has dealt on the margin accepted in the Map and non- Map transactions at page 10 para 6.5.5 which is read as under: ..... X X X X Extracts X X X X X X X X Extracts X X X X
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