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TMI Blog2011 (5) TMI 508X X X X Extracts X X X X X X X X Extracts X X X X ..... has been preferred by the revenue under section 260A of the Income-tax Act, 1961 (in short "the Act") against the order dated 22-10-2009 passed by the Income-tax Appellate Tribunal, Chandigarh Special Bench, Chandigarh (hereinafter referred to as "the Tribunal") in ITA No. 115/Chd./2009, for the assessment year 2004-05, claiming the following substantial question of law :- "Whether on facts and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mination of Arm Length Price qua the international transactions which the assessee entered into with its parent company. The TPO noticed that the assessee had employed Transactions Net Margin Method for the purpose of computing Arm Length Price and did not dispute the same. He further noticed that one of the comparables, out of independent comparable selected by the assessee for the computation of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... de order dated 28-11-2008 partly allowed the appeal granting the benefit of 5 per cent to the assessee under section 92C(2) of the Act and dismissed the same with regard to use of multiple years data and the selection of M/s. Imercius Technologies India Pvt. Ltd. as comparable. Against the order of the CIT(A), the department as well as the assessee filed appeals before the Tribunal. The Tribunal v ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the assessee shall be entitled to produce all relevant material for determination of proper Arm's Length Price and shall co-operate for expeditious disposal of the matter. 5. On a query being put to the learned counsel for the revenue as to what has happened before the Assessing Officer after the remand, she candidly admitted that the order has been passed in favour of the assessee on 11-1- ..... X X X X Extracts X X X X X X X X Extracts X X X X
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