2015 (7) TMI 899

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....Shri Vijay Kumar, CIT, D.R. ORDER Per George Mathan: This is an appeal filed by the assessee against the order passed by the Dispute Resolution Panel dated 23.12.2013 for the assessment year 2009-10. 2. Shri Arvind Sonde, Advocate, represented on behalf of the assessee and Shri Varinder Mehta, CIT, D.R. alongwith Shri Vijay Kumar, CIT, D.R., represented on behalf of the Revenue. 3. ....

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....D.R.P.') was liable to be set aside, in so far as in respect of the main issue being determination of arm's length price in respect of the management Support Services received by the assessee, the D.R.P. had not considered any of the objections of the assessee and had without passing a speaking order confirmed the Transfer Pricing Officer's (hereinafter referred as 'T.P.O') order. It was the furth....

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....cific query as to why the order of the D.R.P. must not be restored to the DRP for re-adjudication and for passing a speaking order. Ld. A.R. on behalf of the assessee did not raise any serious objection. 5. This was al so put to the ld. CIT, D.R., who submitted that the order of the D.R.P. was liable to be upheld and that the Special Counsel was being engaged for represent ing the appeal. It wa....

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....d by the Revenue to the extent of 48.9% of the principal tax and the stay granted by the Tribunal would exceed 365 day's limit by March, 2015. In these circumstances, we are compelled to reject the Revenue's request for adjournment and dispose of the appeal. After considering these submissions of the ld. A.R. and a perusal of the D.R.P.'s order more specifically paras 9, para 31, para 34, para 48 ....