9911796707
TMI Blog2012 (8) TMI 311X X X X Extracts X X X X X X X X Extracts X X X X ..... rse in nature, and is left to the Lower Appellate Authority to redetermine. - IT APPEAL NOs. 826 & 827 OF 2007 - - - Dated:- 10-7-2012 - D.V. SHYLENDRA KUMAR AND B. MANOHAR, JJ. JUDGMENT RE: ITA No. 826/2007 : D.V. Shylendra Kumar, J. - This appeal by the assessee under Section 260-A of the Income Tax Act, 1961 is against the order of the Tribunal dated 12-07-2007 in I T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e 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 the Commissioner of Income Tax (Appeals) and restore the matter to the file of the Assessing officer who may again refer the question of determination of Arm's Length price to the Transfer Pric ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt 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 and reasonable Arm's Length Price should be determined as enjoined by the directions of the Board to its officer. With the above hopeful observation, we remand the matter back to the file of the As ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o 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 the aspects and leaving it open to the assessee to urge all such contentions as are available to the assessee before the authority to which the matter is remanded. RE: I T A No.827/2006 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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