ITAT Remand Case to AO for Determining ALP of Purchase Transaction of FA by Appellant to its Overseas AEs

Denso India Pvt. Ltd Vs DCIT (ITAT Delhi) The issue under consideration is whether rejecting the benchmarking approach and methodology followed by the Appellant for determining the ALP of the transactions pertaining to purchase of fixed assets by the Appellant to its overseas AEs is justified in law? ITAT states that, as regards to this ground, the same has been argued extensively by the Ld. AR. But the fact remains that proper evidences were not produced before the DRP/TPO at the time of the adjudication of this issue by the assessee. The Ld. DR extensively supported the filters adopted by th...