2015 (1) TMI 148

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....PER R.S. SYAL, AM: This appeal by the assessee is directed against the order dated 21.01.2014 passed by the AO u/s 143(3) read with section 144C of the Income-tax Act, 1961 (hereinafter also called 'the Act') in relation to the assessment year 2009-10. 2. The additional ground raised by the assessee challenging the validity of the impugned order on the basis that the same was made in a wrong....

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....Pricing Officer and in turn, made by the Assessing Officer. The assessee is aggrieved against this addition. 5. After considering the rival submissions and perusing the relevant material on record, it is observed that the assessee made payment of the above amount on receipt of technical services pursuant to an Agreement dated 26.04.2006, a copy of which has been placed on page 196 of the paper ....

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....determination of ALP of this international transaction in accordance with law, after allowing a reasonable opportunity of being heard to the assessee. 6. The only other ground is against the addition of Rs. 60 lac made by the AO u/s 14A of the Act. Here again, we find that similar disallowance was made by the AO. When the matter came up before the Tribunal, this issue was also sent back for a f....