Haier Appliances India (P.) Ltd v. Dy.CIT (2024) 298 Taxman 228 (Delhi)(HC)

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Inconistent finding-Matter remanded to the Tribunal for considering appeal afresh.[S. 254(1),254(2, 260A]

Tribunal had firstly observed that RPM as adopted by assessee would clearly be applicable, however, in very next paragraph, it had proceeded to undertake quantification of arm’s length price in relation to AMP expenditure, since aforesaid observations were clearly inconsistent and incompatible, matter was to be remanded for considering appeal afresh.   (AY. 2008-09)