https://www.taxtmi.com/caselaws?id=375193 In a transfer pricing dispute under section 260A of the Income-tax Act, 1961, the Bombay HC clarified that where the issue whether AMP expenditure constitutes an international transaction was not decided in the impugned Tribunal order, but the Assessing Officer addressed it on remand and the second round was pending, the Tribunal was the proper forum to determine that question. It further stated that issues concluded in the first round, other than those expressly remanded, could not be reopened. The matter was therefore sent back to the Tribunal for decision on the international transaction issue in the second round, without re-adjudicating other concluded issues. en-us Wed, 06 Feb 2019 00:00:00 +0530 Fri, 15 Feb 2019 08:10:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=375193 In a transfer pricing dispute under section 260A of the Income-tax Act, 1961, the Bombay HC clarified that where the issue whether AMP expenditure constitutes an international transaction was not decided in the impugned Tribunal order, but the Assessing Officer addressed it on remand and the second round was pending, the Tribunal was the proper forum to determine that question. It further stated that issues concluded in the first round, other than those expressly remanded, could not be reopened. The matter was therefore sent back to the Tribunal for decision on the international transaction issue in the second round, without re-adjudicating other concluded issues. Case-Laws Income Tax Wed, 06 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=375193