2022 (1) TMI 1026

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... correctness of granting risk adjustment to the assessee by Ld DRP - HELD THAT:- Since the entire transfer pricing dispute has been resolved under MAP proceedings, this ground of the revenue does not require to be adjudicated. Accordingly, we reject the same. Deduction allowed u/s 10A - whether the Ld CIT(A) was justified in holding that the expenses incurred in foreign currency is required t .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... -DR For the Assessee : Smt.Rashmi, Advocate ORDER PER B.R.BASKARAN, AM : The assessee has filed appeal challenging the assessment order dated 28-01-2016 passed by the AO u/s 143(3) r.w.s 144C(13) of the Act for the assessment year 2011-12 in pursuance of directions given by Ld Dispute Resolution Panel (DRP). The revenue has filed appeal challenging certain directions given by .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... y Ld DRP. Since the entire transfer pricing dispute has been resolved under MAP proceedings, this ground of the revenue does not require to be adjudicated. Accordingly, we reject the same. 5. The next issue relates to the deduction allowed u/s 10A of the Act, i.e, whether the Ld CIT(A) was justified in holding that the expenses incurred in foreign currency is required to be reduced from both ex .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X