https://www.taxtmi.com/caselaws?id=354422 The High Court held that the Tribunal was not justified in remanding the transfer pricing matter for a fresh benchmarking exercise when the surviving dispute was limited to the inclusion and exclusion of comparables. Since the exercise turned on functional, asset and risk comparison under Rule 10B(2) and Rule 10B(3) of the Income-tax Rules, the Tribunal could have decided the issue on merits without reopening the entire matter before the Transfer Pricing Officer. The remand direction was therefore unsustainable and was set aside in favour of the assessee. en-us Mon, 18 Sep 2017 00:00:00 +0530 Sat, 27 Jan 2018 08:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=354422 The High Court held that the Tribunal was not justified in remanding the transfer pricing matter for a fresh benchmarking exercise when the surviving dispute was limited to the inclusion and exclusion of comparables. Since the exercise turned on functional, asset and risk comparison under Rule 10B(2) and Rule 10B(3) of the Income-tax Rules, the Tribunal could have decided the issue on merits without reopening the entire matter before the Transfer Pricing Officer. The remand direction was therefore unsustainable and was set aside in favour of the assessee. Case-Laws Income Tax Mon, 18 Sep 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=354422