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TMI Blog2017 (11) TMI 1871X X X X Extracts X X X X X X X X Extracts X X X X ..... cson Mobile Communications (India) Pvt. Ltd. v. CIT [ 2015 (3) TMI 580 - DELHI HIGH COURT] held that in matters of transfer pricing the first exercise that is to be undertaken is to determine if in fact there existed an international transaction between the Assessee at its Associated Enterprise. Only if the said question is answered in the affirmative, the further question of determining its arm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion) in ITA 972/2017 Exemptions are allowed subject to all just exceptions. ITA No. 971/2017 ITA No.972/2017 1. Issue notice. Mr. Asheesh Jain, Advocate accepts notice. 2. With the consent of the parties, the matters are heard. 3. These two appeals both by the assessee concern the same Assessment Year 2011-2012. The issue involved is the transfer pricing adjustment due ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... urt. 5. The assessee s grievance is that, firstly, for another AY 2010-11, this Court restored its appeal before the ITAT for a fresh finding on the issues involved. The second ground urged is with respect to the matter which had obtained finality and for which the ITAT did not render any finding; the matter ought not to be remitted to the AO. 6. We notice that this Court in ITA Nos.432/20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ternational transaction between the Assessee at its Associated Enterprise. Only if the said question is answered in the affirmative, the further question of determining its arm's length price would arise. Counsel on both sides state that all the necessary documents and information for determining the above question already form part of the record of the case in the ITAT. 5. In view of the abov ..... X X X X Extracts X X X X X X X X Extracts X X X X
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