2016 (8) TMI 1274

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..... tested party - transfer pricing analysis and determination of ALP - ITAT remitted the matter for consideration of the most appropriate method as well as question of the appropriate comparables applicable - assessee approached this court against the observations and findings of the ITAT to the effect that the Foreign AE cannot be considered as a tested party as per sec 92B Held that:- This court n .....

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..... ng Counsel appearing on behalf of the respondents accepts notice. The question of law which the assessee/appellant argues in this appeal for AY-2009-2010 is regarding the appropriateness and correctness of treating the Foreign/Associated Enterprises (AEs) as a tested party. The assessee's transfer pricing analysis and determination of ALP led it to approach to ITAT which by impugned order has rem .....

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