Rio Tinto India (P.) Ltd. v. DCIT (2020) 182 ITD 389 (Delhi)(Trib.)

S. 144C : Reference to dispute resolution panel-Speaking order-Functionally different-Remanded to DRP to pass speaking order. [S. 92C]

Tribunal held that it was incumbent upon DRP to consider objections raised by assessee and then decide same. Accordingly  the order was to be set aside and, matter was to be remanded back to DRP with a direction to consider whether concerns finally selected by TPO were functionally comparable or not. (AY. 2011-12)