The Tribunal set aside the order on the issue of addition towards transfer pricing adjustment in the international transaction under dispute and remit the matter to the file of AO/TPO for fresh determination of its ALP in consonance with the observations and directions needless to say the assessee will be allowed a reasonable opportunity of being heard in such fresh proceedings. (AY. 2006-07)
CEVA Freight India (P) Ltd. v. Dy. CIT (2018) 192 TTJ 887/ 172 DTR 55 (Delhi)(Trib.)
S. 92C : Transfer pricing -Arm’s length price- Matter was remanded .