2016 (7) TMI 1469

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...., Manasvini Bajpai For the Respondent :- S.C.,Gaurav Mahajan ORDER 1. Heard Sri Deepak Chopra, Advocate, assisted by Sri Suyash Agarwal, learned counsel for appellant and Sri Gaurav Mahajan for respondents. 2. This appeal under Section 260-A of the Income Tax Act, 1961 (hereinafter referred to as 'Act 1961') has arisen from judgment and order dated 07.01.2016 passed by Income T....

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....ries but this does not make Assessee a manufacturer. Instead of buying goods off the shelf, it is buying spares by placing job work order from manufacturer. But simultaneously Assessee was also laying down design, specification etc. which was the job of manufacturer of Car who does such function. Tribunal having said so, came to the conclusion that the matter has not been properly examined by Asse....

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....el (in short 'DRP') or the Tribunal. 7. The substantial questions of law therefore, sought to be raised in this appeal is " when a remand order is passed to examine substantial factual issues, Assessing Officer/TPO should be allowed to consider the matter/issues on which remand is made by taking into account entire relating aspects or scope of enquiry should be restricted by the observa....