2018 (9) TMI 79

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....it Chakravarty with Ms Shraddha Swarup & Mr. Abhishek Tilak i/by Rajan Mishra for the Respondent. P.C: 1. By this appeal, the Revenue has challenged the order passed on 22.4.2015. That order was passed by the Income Tax Appellate Tribunal, Bench at Mumbai. 2. The Assessment Year is 2005-06. 3. The respondent/assessee received brokerage from its parent company S.G. Paris. The assessee was direc....

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....et and 0.05 for futures. On account of this, addition of Rs. 2,89,82,746/was made. 5. Aggrieved by this assessment order of 27122007, the assessee preferred an appeal to the First Appellate Authority and he confirmed the addition. 6. Further aggrieved, the assessee approached the Tribunal and the order under appeal was delivered in favour of the assessee. 7. We have heard Mr. Kotangle, appearin....

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....structions were applicable. If they were applicable, then, there ought to be some solid ground for ignoring a mandate flowing therefrom. The mandate is that the Assessing Officer should make a reference to the Transfer Pricing Officer. That is to make the transfer pricing adjustment. In this case, no such reference was made despite the facts warranting so. There is no acceptable or justifiable rea....