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| The Tax Publishers2020 TaxPub(DT) 5393 (Del-HC) INCOME TAX ACT 1961
Section 92C
Since the order of Tribunal remanding the matter back to the TPO and directing it to consider the combined effect of 14 factors for determining the cost/ value of international transactions was already set aside by the order dt. 13-1-2016 in ITA Nos. 349/2015 and 388/2015, TPO was directed to decide the remand in accordance with said order.
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Transfer pricing - Computation of ALP - TP adjustment -
Revenue filed appeal against the order of Tribunal remanding the matter back to the TPO and directing it to consider the combined effect of 14 factors for determining the cost/ value of international transactions in accordance with the order passed by Special Bench immediately preceding year of -assessee in LG Electronics India Pvt. Ltd. v. ACIT (2013) 152 TTJ (Del-Trib) (SB) 273 : 2013 TaxPub(DT) 634 (Del-Trib). Held: The said judgment of the Special Bench had already been set aside by the Order, dt. 13-1-2016 in ITA Nos. 349/2015 and 388/2015. Further, assessee also had no objection if the TPO was directed to decide the remand in accordance with said order. Accordingly, the impugned order of Tribunal was set aside and the TPO was directed to decide the matter in accordance with the directions contained in ITA Nos. 349/2015 and 388/2015.
REFERRED :
FAVOUR : Against the assessee.
A.Y. :
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