Shanti Prime Publication Pvt. Ltd.
Section 92C read with section 144C of the Income Tax Act, 1961 — Transfer Pricing — Computation of arms length price — The directions passed by the DRP under section 144C(5) are not speaking about what objections were raised by the assessee and how they have been found to be not acceptable, the DRP has simply observed that the TPO has given reasons for rejecting the comparables and by the AO in the draft order, therefore, the order passed by the DRP is a non speaking order on the issues raised by the assessee not stating objections raised by the assessee and the reasons have also not been given as simply the order of the TPO and AO are referred — Sun tec Business Solutions P. Ltd. vs. Deputy Commissioner of Income tax [2018] 173 ITD 185(Cochin - trib)