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TMI Blog2022 (12) TMI 1204X X X X Extracts X X X X X X X X Extracts X X X X ..... and issue-in-dispute involved in relation to adjustment to the deemed international transactions is restored back to the file of the Ld. AO/TPO for deciding afresh after providing adequate opportunity of being heard to the assessee. The ground of the appeal of the assessee accordingly allowed for statistical purposes. - ITA No. 7894/MUM/2019 - - - Dated:- 19-5-2022 - SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAHUL CHAUDHARY (JUDICIAL MEMBER) Assessee by : Mr. M.P. Lohia/ Mr. Hemen Chadariya, ARs Revenue by : Dr. Satya Pinisetty, CIT-DR ORDER PER OM PRAKASH KANT, AM This appeal by the assessee is directed against final assessment order dated 31/10/2019 passed by the Ld. Asst. Commissioner of Income-Ta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the AE from the broadcasters were linked to the production fees to be received by the Appellant, it was in the AE's interest that the Appellant receives an appropriate share of production fees from the broadcasters 6. Without prejudice to the above, the learned A erred in making transfer pricing adjustment in contravention of the Hon ble DRP directions which directed the arms-length price to be equivalent to the cost of production and rejecting external TNMM applied by the TPO, thereby making the assessment order illegal and void. 7. The learned AO failed to appreciate the directions of the Hon'ble DRP that the Appellant should have recovered the cost of production from the deemed AEs, and that the cost of production is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sourced by the AE from the aforementioned broadcaster. 2. Format agreement between Fremantle media Ltd and ZEE entitlement enterprise limited for show Scars of life . 3.1 In view of the above additional evidences submitted, the Ld. counsel of the assessee submitted that issue-in-dispute may be restored back to the file of the Ld. AO/TPO for deciding afresh in the light of above additional evidences. 4. The Ld. DR also did not object to the above request of the Ld. counsel of the assessee. 5. We have heard rival submission of the party and perused the relevant material record. For determination of arm s length price of the deemed international transactions, it is important to go through the agreement entered between the AE ..... X X X X Extracts X X X X X X X X Extracts X X X X
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