Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Enhancement of income - Exercise of power by the CIT(A) u/s 251 - introducing new source of income - It is not open for the ld. CIT(A) to travel outside the assessment order with a view to find out new sources of income. There must be something in the assessment order to show that Ld. AO had applied his mind to the particular subject matter with a view to its taxability or its nontaxability and not to any incidental connection. - order of the CIT (A) set aside - Additions deleted - AT
Enhancement of income - Exercise of power by the CIT(A) u/s 251 - introducing new source of income - It is not open for the ld. CIT(A) to travel outside the assessment order with a view to find out new sources of income. There must be something in the assessment order to show that Ld. AO had applied his mind to the particular subject matter with a view to its taxability or its nontaxability and not to any incidental connection. - order of the CIT (A) set aside - Additions deleted - AT
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