TPO made addition by applying average margin of 21.18% to total cost. keeping in view exceptional circumstances faced by assessee during period when proceedings were under way with Revenue for framing assessments as well during first appellant proceedings, due to collapse of Lehman group worldwide, assessee could not make effective representations before authorities below and interest of justice demand that assessee be given one more opportunity to present all evidences and explanations in its support before authorities below. Accordingly the matter is remanded to the AO.(AY. 2007-08)
Lehman Brothers Securities (P) Ltd v. DCIT (2018) 192 TTJ 58 (UO) (Mum.)(Trib.)
S. 92C : Transfer pricing—adjustment—financial advisory solutions in the field of investment banking division–TNMM method entry level- Effective representation was not made before TPO or CIT(A) –Matter remanded to the AO / TPO.