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| The Tax Publishers2021 TaxPub(DT) 0721 (Pune-Trib) INCOME TAX ACT, 1961
Section 92C
Where neither AO/TPO/CIT(A) gave any finding in respect of inclusion or exclusion of comparables while confirming the upward adjustment to the arm's length price of international transactions in manufacturing segment, matter was remanded to the file of TPO for consideration afresh.
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Transfer pricing - Computation of ALP - Benchmarking of comparables - Upward adjustment
Assessee filed appeal against the action of CIT(A) in confirming the upward adjustment to the arm's length price of international transactions without giving any finding in respect of the action of TPO in exclusion/inclusion of comparables. Held: Neither AO/TPO/CIT(A) gave any finding in respect of inclusion or exclusion of comparables while confirming the upward adjustment to the arm's length price of international transactions in manufacturing segment. Therefore, it was proper to remand the matter to the file of TPO for determining the ALP of said international transactions after consideration afresh.
REFERRED :
FAVOUR : Matter remanded.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 43B
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