2015 (12) TMI 1076

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ne i/b.Padma Divakar For The Respondent : Mr. Madhur Agarwal with Mr. Atul Jasani P.C: This Appeal under Section 260A of the Income Tax Act, 1961 (the Act) challenges the order dated 27th November, 2011 passed by the Income Tax Appellate Tribunal (the Tribunal) for the Assessment Year 200708. 2 Mr. Kotangale, learned Counsel appearing for the Revenue urges the following reframed questions of ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... manufacture, supply, erection and commissioning of sugar plants, cement plants, etc. During the subject Assessment Year, the RespondentAssessee had International Transaction with its Associated Enterprises (AE) in respect of import of spares and equipments, royalty and project engineering, manufacturing drawings, settlement for liquidated damages and interest on delayed payments. (b) The TPO on....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....he Assessee's appeal before it. (d) The grievance of the Revenue before us is that the adjustment is not to be restricted only in respect of transactions entered into with the AE. All the transactions of the RespondentAssessee would have necessarily be varied/ adjusted by the margin arrived at by the TPO to arrive at the ALP. (e) We find that in terms of Chapter X of the Act, redeterminati....