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TMI Blog2012 (7) TMI 663X X X X Extracts X X X X X X X X Extracts X X X X ..... ndent relevant information of comparable uncontrolled transactions. Let the revenue authorities determine fresh ALP in the light of above observation and in accordance with the regulations. - ITA No.826/2007 c/w ITA No.827/2007 - - - Dated:- 10-7-2012 - MR.JUSTICE D.V.SHYLENDRA KUMAR, MR. JUSTICE B.MANOHAR. JJ. For Appellant: SMT.S.R.ANURADHA, ADVOCATE For Respondent: SRI.M.V.SESHAC ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... appeal, the company in question has got merged with another company and therefore, the successor company may have to come on record. For such reason, she seeks a short accommodation. 6. On the other hand, Sri.Seshachala, learned counsel has drawn our attention to paragraph 170 of the order of the Tribunal reading as under: In the light of above discussion, we set aside the impugned order of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cussed above, any changes in the most appropriate method of computing the arms length price is to be dealt with by way of a speaking order. T.P.O. is also at liberty to collect independent relevant information of comparable uncontrolled transactions. Let the revenue authorities determine fresh ALP in the light of above observation and in accordance with the regulations. Be that as it may a fair an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... examination by the High Court in an appeal under Section 260-A of the Act, unless any part of the remand order suffers from a patent illegality or is an order perverse in nature, and is left to the Lower Appellate Authority to redetermine. 9. in this view of the matter, we do not propose to examine this appeal on merits any further but dismiss the appeal without expressing any opinion on any of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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