9911796707
TMI Blog2015 (1) TMI 148X X X X Extracts X X X X X X X X Extracts X X X X ..... s been placed on page 196 of the paper book. Such payment was made in consideration of receipt of technical services in the preceding year as well, for which the TPO proposed and the AO made transfer pricing adjustment in the same manner in which it has been done for the instant year. The assessee preferred appeal against that order and the Tribunal vide its order [2014 (2) TMI 380 - ITAT DELHI] h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Respondent : Shri Yogesh Verma, CIT ORDER PER R.S. SYAL, AM: This appeal by the assessee is directed against the order dated 21.01.2014 passed by the AO u/s 143(3) read with section 144C of the Income-tax Act, 1961 (hereinafter also called the Act ) in relation to the assessment year 2009-10. 2. The additional ground raised by the assessee challenging the validity of the impugne ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cing adjustment of ₹ 98.66 lac was proposed by the Transfer Pricing Officer and in turn, made by the Assessing Officer. The assessee is aggrieved against this addition. 5. After considering the rival submissions and perusing the relevant material on record, it is observed that the assessee made payment of the above amount on receipt of technical services pursuant to an Agreement dated 26. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... order and remit the matter to the file of the AO/TPO for a fresh determination of ALP of this international transaction in accordance with law, after allowing a reasonable opportunity of being heard to the assessee. 6. The only other ground is against the addition of ₹ 60 lac made by the AO u/s 14A of the Act. Here again, we find that similar disallowance was made by the AO. When the mat ..... X X X X Extracts X X X X X X X X Extracts X X X X
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