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TP Adjustment - Adjustment in respect of credit period - the ...


Transfer Pricing Dispute Overlooked by CIT(A); Case Remanded for Fresh Review to Ensure Fair Hearing for Assessee.

May 31, 2022

Case Laws     Income Tax     AT

TP Adjustment - Adjustment in respect of credit period - the contentions of Revenue and Assessee have not been thoroughly examined by the Ld. CIT(A) in proper perspective. We also observe that no remand report was called for by the Ld. CIT(A) to appreciate the contentions of Revenue as well as the Assessee. In the interest of justice we restore this ground to the file of the Ld. AO/TPO for denovo adjudication in accordance with law after providing adequate opportunity of being heard to the assessee. Grounds of appeal of the Revenue is allowed for statistical purpose. - AT

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