Held that the orders passed by the Transfer Pricing Officer, the Dispute Resolution Panel and the Tribunal had proceeded on an assumption which were ex facie incorrect. Accordingly, the matter was restored before the Transfer Pricing Officer, to the limited extent, to examine the inclusion of e4e as a comparable entity.(AY.2013-14)
Sequential Technology International India Pvt. Ltd. v. Add. CIT (2025)472 ITR 753/ 169 taxmann.com 256 (Delhi)(HC)
S. 92CA : Transfer pricing Reference to Transfer Pricing Officer- Arm’s Length price- Avoidance of tax- Comparables- Objections of assessee on account of functional dissimilarities is not considered by Tribunal-Matter remanded to Transfer Pricing Officer.[S.92CA(3), 254(1)]
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