2017 (5) TMI 1828

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..... anded to TPO the issues regarding the working out of the transfer pricing adjustment on the basis of certain parameters mentioned therein. HELD THAT:- As pointed out by Assessee, that even if the Profit Level Indicator (PLI) is revised on the basis of the remand order of the ITAT, the PLI based on Operative Profit (OP)/cost will work out to -0.04%. Therefore, the remand order does not give rise to .....

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..... for the purpose of determining the arm s length price of international transaction involving the Assessee. The ITAT by the impugned order remanded to the Transfer Pricing Officer (TPO) the issues regarding the working out of the transfer pricing adjustment on the basis of certain parameters mentioned therein. It is pointed out by Mr. Satyen Sethi, learned counsel for the Assessee, that even if the .....

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