Transfer pricing and Section 80HHE questions left unresolved as most issues were not entertained or sent back for reconsideration.

The Bombay High Court did not finally adjudicate most of the Revenue's proposed questions. It declined to entertain several issues, treating some as covered by earlier precedent or by the Tribunal's factual findings. The transfer pricing question concerning consultancy charges was restored to the Tribunal for fresh consideration in light of the retrospective amendment to Section 92B(1). The issue relating to the Sweden branch losses was not pressed. The appeal was admitted only on the surviving Section 80HHE computation question, but this order records no substantive merits determination on that point, leaving it pending for further consideration.

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Issues: Whether the Revenue's questions relating to set-off of Section 10A unit losses, transfer pricing adjustment on consultancy charges, eligibility of newly established units for Section 10A deduction, losses of the Sweden branch, and the Section 80HHE computation issue were finally adjudicated in this order.

Analysis: Questions (a), (b), (d), (g), (h) and (i) were not entertained by the Court, with some being treated as covered by earlier precedent or supported by findings of fact recorded by the Tribunal. Question (c) was restored to the Tribunal for fresh decision in light of the retrospective amendment to Section 92B(1). Question (e) was not pressed. The only surviving question, question (f), was the one on which the appeal was admitted.

Conclusion: No substantive final adjudication was rendered on the merits of the surviving question in this order; the matter remained pending for consideration on question (f).

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