https://www.taxtmi.com/caselaws?id=390706 Relief granted by the first appellate authority on the basis of bills, vouchers and TDS records not examined by the Assessing Officer was held unsustainable for non-compliance with Rule 46A(3), and the deletion of disallowance was remitted for fresh examination. The finding that the foreign buyer was not an associated enterprise was also set aside because there was no categorical determination of the conditions in Section 92A(2), requiring reconsideration. Transfer pricing adjustments relating to service income and export transactions were likewise not upheld, as the appellate order did not contain a clear, reasoned arm's length finding. All disputed additions and transfer pricing matters were restored for decision afresh. en-us Tue, 07 Jan 2020 00:00:00 +0530 Fri, 10 Jan 2020 06:55:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=390706 Relief granted by the first appellate authority on the basis of bills, vouchers and TDS records not examined by the Assessing Officer was held unsustainable for non-compliance with Rule 46A(3), and the deletion of disallowance was remitted for fresh examination. The finding that the foreign buyer was not an associated enterprise was also set aside because there was no categorical determination of the conditions in Section 92A(2), requiring reconsideration. Transfer pricing adjustments relating to service income and export transactions were likewise not upheld, as the appellate order did not contain a clear, reasoned arm's length finding. All disputed additions and transfer pricing matters were restored for decision afresh. Case-Laws Income Tax Tue, 07 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=390706