2012 (7) TMI 663

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....ADVOCATE   For Respondent: SRI.M.V.SESHACHALA, ADVOCATE   JUDGMENT   RE:: I T A NO. 826/2007   This appeal by the assessee under Section 260-A of the Income Tax Act, 1961 is against the order of the Tribunal dated 12-07-2007 in I T A No.584/Bang/2006.   2. The assessee is a company engaged in the business of development and export of software. The assessment....

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....ading as under:   "In the light of above discussion, we set aside the impugned order of the Commissioner of Income Tax (Appeals) and restore the matter to the file of the Assessing officer who may again refer the question of determination of Arm's Length price to the Transfer Pricing Officer. In our view, Transfer Pricing Officer should use his power and first call upon the taxpayer to fur....

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....e light of above observation and in accordance with the regulations. Be that as it may a fair and reasonable Arm's Length Price should be determined as enjoined by the directions of the Board to its officer. With the above hopeful observation, we remand the matter back to the file of the Assessing Officer."   7. We notice that in this appeal, the assessee has raised as many as 30 substanti....

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....amine this appeal on merits any further but dismiss the appeal without expressing any opinion on any of the aspects and leaving it open to the assessee to urge all such contentions as are available to the assessee before the authority to which the matter is remanded. RE:: I T A No.827/2006 10. This appeal by the very assessee as above in respect of the assessment year 2002-03, insofar as it ....