2020 (2) TMI 728

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.... Narasimha Sarma JUDGMENT: (Per MSR,J) This appeal is filed under Section 260-A of the Income Tax Act, 1961 challenging the order dt.15-02-2019 in I.T.A.No.2022/Hyd/2017 of the Income Tax Appellate Tribunal, Hyderabad Bench-A, Hyderabad in relation to the respondent-assessee for the year 2013-14. 2. The respondent-company is engaged in the business of manufacturing high performance flexib....

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....rdance with the proposed adjustment, the A.O. passed the draft assessment order and the assessee preferred its objections before the D.R.T.   6. The D.R.T. confirmed the T.P.O's order and in accordance therewith, the final assessment order was passed. 7. The assessee then filed the appeal before the Tribunal. 8. It was contended before the Tribunal by the assessee that the issue of d....

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....gy, it has paid the royalty. It then referred to decisions of the Coordinate Bench of the Tribunal at Bangalore. In a similar case, the Tribunal had remitted the issue to the file of the A.O. to determinate the arm's length price of royalty by adopting TNMM after giving fair opportunity for hearing. Thus, the Tribunal has only remitted the matter back to the file of AO/TPO and did not adjudicate a....