Monday 20 January 2014

ITAT remands back matter to enquire into an issue directly relevant to TP adjustments and not dealt

IT/ILT : Where assessee raised an additional ground before Tribunal that AEs were independent parties when revenue sharing agreement were entered, therefore, transactions between them should be regarded as carried out under uncontrolled conditions, as the issue want to very root of TP adjustment, it was to be admitted


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