Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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The assessee raised an issue before the CIT(Appeals) which was not adjudicated. The assessee can raise this unadjudicated issue before the Tribunal by way of an application u/r 27 of ITAT Rules, 1963, as per judicial precedents. The issue relates to the legality of the penalty notice issued u/s 274 read with Sections 270A/271AAB, without specifying the relevant limb. Since the CIT(Appeals) did not decide this legal issue, and the assessee raised it for the first time before the Tribunal, the file needs to be remanded to the CIT(Appeals) to consider the preliminary legal issue regarding the validity of penalty proceedings initiated based on the vague notice.
The assessee raised an issue before the CIT(Appeals) which was not adjudicated. The assessee can raise this unadjudicated issue before the Tribunal by way of an application u/r 27 of ITAT Rules, 1963, as per judicial precedents. The issue relates to the legality of the penalty notice issued u/s 274 read with Sections 270A/271AAB, without specifying the relevant limb. Since the CIT(Appeals) did not decide this legal issue, and the assessee raised it for the first time before the Tribunal, the file needs to be remanded to the CIT(Appeals) to consider the preliminary legal issue regarding the validity of penalty proceedings initiated based on the vague notice.
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