The Assessee, Wipro GE Healthcare Pvt. Ltd. is a joint venture between General Electric Co USA and Wipro Ltd. It has been stated to be engaged in contract manufacturing of medical diagnostic imaging equipment, ultrasound systems, patient monitoring and X-Ray systems, provision of engineering and software services and distribution of medical diagnostic imaging equipment, therapy equipment and life science products. During the year under consideration assessee entered into international transactions with its AE and specified domestic transactions.
In respect of transfer pricing addition made by Ld.AO. It is observed that DRP/TPO for years under consideration did not consider objections raised by assessee against comparables selected by TPO and simply followed DRP directions issued for AY 2014-15.
The Coram consisting of George George K. and B.R. Baskaran deemed it fit and proper to remit the issues to the file of AO/TPO for taking necessary action of passing a speaking order by granting fair opportunity to assessee of being heard.
The ITAT also observed that all these are pending before lower authorities and found no reason to adjudicate these issues at this stage.
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