SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
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Reopening of assessment u/s 147 - addition u/s 68 - As the failure on the part of the A.O to facilitate a cross-examination of the aforementioned persons, and also make available complete copies of their statements would have undeniably made it impractical for the assessee company to defend its case and rebut the adverse inferences which the A.O would have drawn by pressing into service the statements of the aforementioned persons, therefore, in our considered view the matter in all fairness would require to be revisited by the A.O. - AT
Reopening of assessment u/s 147 - addition u/s 68 - As the failure on the part of the A.O to facilitate a cross-examination of the aforementioned persons, and also make available complete copies of their statements would have undeniably made it impractical for the assessee company to defend its case and rebut the adverse inferences which the A.O would have drawn by pressing into service the statements of the aforementioned persons, therefore, in our considered view the matter in all fairness would require to be revisited by the A.O. - AT
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