2020 (1) TMI 1190

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....is appeal has been filed against the order dated 16.11.2018 passed by the Income Tax Appellate Tribunal ,Delhi Bench 'I-1' New Delhi in ITA No. 6366/DEL/2017 for the assessment year 2013-14 whereby the matter was remanded back to the Transfer Pricing Officer (TPO) for fresh consideration for setting aside the impugned order. The appellant has claimed the following substantial question of l....

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....re that the appellant filed his return of income for the assessment year 2013-14 on 29.11.2013 and claimed certain expenses, the same were disallowed by the TPO by introducing the 'CUP Method' (as opposed to the earlier TNMM Method which had been used in the past) and by resorting to the ALP. By the impugned order, the Tribunal has held that on fact there was no good reason for the TPO to ....