CET Power Solutions India P. Ltd. v. Dy. CIT (2023)106 ITR 68 (SN)/ 153 taxmann.com 553 (Chennai ) (Trib)

S. 144C: Reference to dispute resolution panel-Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Remand order-Order passed by Assessing Officer giving effect to order of Dispute Resolution Panel without understanding Tribunal’s order-Matter remanded to Assessing Officer for adjudication afresh. [S. 92CA]

Held  that the order passed by the Assessing Officer giving effect to the order of Dispute Resolution Panel dated December 28, 2017 was passed without understanding the Tribunal’s order and this was a curable defect. Accordingly, the matter had to go back to the Assessing Officer for adjudication afresh. (AY.2011-12)