Mahle Behr India Ltd. v. DCIT (2021) 188 ITD 769 (Pune)(Trib.)

S. 92C : Transfer pricing-Arm’s length price-Order passed without giving any finding-Matter remanded. [S. 254(1)]

Held that Assessing Officer/TPO/Commissioner (Appeals) did not give any finding in respect of inclusion or exclusion of comparables, but made T.P. adjustment. Matter remanded (AY. 2010-11)