Held that the Tribunal has jurisdiction to allow Department to raise new ground and remand matter to Transfer Pricing Officer for enquiry and action. Followed CIT v. Assam Travels Shipping Service (1993) 199 ITR 1 (SC). (AY.2011-12)
PCIT v. Apollo Tyres Ltd. (No. 3) (2022) 447 ITR 431 (Ker.)(HC)
S. 254(1) : Appellate Tribunal-Powers-Tribunal has jurisdiction to allow Department to raise new ground and remand matter to Transfer Pricing Officer for enquiry and action. [S. 92C]