Friday 11 October 2013

DRP has to pass a speaking order even if TPO doesn't take up impugned matter independently

IT/ILT: Where TPO clubbed payment for allied services with royalty paid by assessee and determined ALP at NIL, in view of fact that TPO discussed only transaction of royalty payment throughout his order and had not taken up any other allied payments independently, DRP was not justified to sustain addition with regard to other allied payment without giving any cogent reason


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