Tribunal held that in view of the fact that the assessee has entered into APA with the Board, for the subsequent asessment years, without commenting on the merits of the adjustment made the Tribunal remitted the matter to CIT (A ) to re-adjudicate the issue in accordance with the aforesaid directions. (AY. 2010-11)
Tieto It Services India (P) Ltd. v. DCIT (2018) 163 DTR 60 / 196 TTJ 126 (Pune)(Trib.)
S. 92C : Transfer pricing–Arm’s length price-Adjustment of Management Support Service fee-APA with the Board, for the subsequent assessment years- Matter remanded to CIT(A)