Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Revision u/s 263 or appeal-able order before CIT(A) u/s 246A - Subject matter of revision was limited - Doctrine of merger - CIT(A) and ITAT rejected the appeal of assessee - appeal is maintainable in respect of the subject matter, which does not pertain to grounds u/s 263 of the Act. The CIT(A) therefore, ought to have adjudicated the appeal on merits to the aforesaid extent. - HC
Revision u/s 263 or appeal-able order before CIT(A) u/s 246A - Subject matter of revision was limited - Doctrine of merger - CIT(A) and ITAT rejected the appeal of assessee - appeal is maintainable in respect of the subject matter, which does not pertain to grounds u/s 263 of the Act. The CIT(A) therefore, ought to have adjudicated the appeal on merits to the aforesaid extent. - HC
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