TPO directed to examine proper facts and fix ALP of credit risk assessment exp. charged by HO to Ind

IT/ILT : Where assessee, a non-resident bank, charged credit risk assistance expenses from Indian branch separately in same invoice in which it had allocated certain expenses as share of Indian branch in Head Office expenses and, therefore, TPO opined that ALP of seperately claimed expenses was nil, in absence of assessee's explanation and any certificate issued by auditor of Head Office in support of expenses in dispute, matter was to be remanded back for disposal afresh