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of Transfer Pricing Adjustment on Delayed Receipt of Export Proceeds - notional interest - The Appellate Tribunal found that the CIT(A) had dismissed the new contention of treating receivables from AEs and non-AEs equally without proper examination, relying on a judgment that didn't restrict the assessee from raising new arguments. Noting that the previous judgment cited by the CIT(A) was not applicable in the current case, the Tribunal deemed the dismissal unjustified. Consequently, the matter was remanded back to the CIT(A) for a fresh examination, allowing the assessee to present all relevant contentions and evidence.
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