2016 (9) TMI 1293

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..... spondent :  Mr. Ashok K. Manchanda, Sr. Standing Counsel with Ms. Lakshmi Gurung, Jr. Standing Counsel. O R D E R The matter is listed today as 13.09.2016 was declared holiday on account of „Id-ul-Zuha‟. The question of law sought to be urged is: - "whether in the circumstances of the case the ITAT acted correctly in upholding the transfer pricing adjustment made in respect o .....

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..... are to be treated on an application of the rule enunciated in Sony Ericsson (supra) would have to be decided by the concerned TPO. Having regard to the facts of the case - as discernable from the ITAT‟s order specially paragraph 3 & 4, we are of the opinion that the matter should be remitted for proper investigation in the first instance to the ITAT. It is so directed. The appeal is allowe .....

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