TaxTMI 
TaxTMI 
2017 (7) TMI 1213
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....ER 1. The present appeal pertains to Assessment Year 200809. 2. The learned Counsel for the appellant submits that the Tribunal was not justified in setting aside the issue of Transfer Pricing Adjustment, relating to International Transaction to the record of the Assessing Officer to examine the relevant facts and then decide the functional comparable of M/s. Cosmic Global Ltd. with the assessee....
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....y bound to maintain the documents as per Rule 10D of the Income Tax Rules. In the absence of the assessee maintaining the said documents and not providing it, the Tribunal was not justified in setting aside the issue of Transfer Pricing Adjustment. According to the learned Counsel, the Tribunal was not justified in directing the Assessing Officer / TPO to determine the ALP interest by considering ....
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.... this Court in Income Tax Appeal No.1320 of 2012, decided on 3rd February, 2015. After remanding the matter, the Assessing Officer has now decided the issue. 5. We have considered the submissions. So far as M/s. Cosmic Global Ltd. is concerned, the Tribunal has come to the conclusion that the nature of business of said M/s. Cosmic Global Ltd. was distinct from the one carried out by the assessee ....