Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
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ITAT remanded the case to the Addl./Joint CIT(A) to determine the validity of an adjustment under section 143(1)(a) without a prior show cause notice. The tribunal found potential procedural irregularities in the tax assessment, specifically questioning whether a mandatory notice was issued before making the adjustment. The appellate authority was directed to ascertain the factual circumstances, particularly examining whether the absence of a show cause notice renders the tax adjustment invalid. The assessee's appeal was allowed for statistical purposes, with instructions to comprehensively review the procedural compliance and potential exemption allowability based on the audit report filing.
ITAT remanded the case to the Addl./Joint CIT(A) to determine the validity of an adjustment under section 143(1)(a) without a prior show cause notice. The tribunal found potential procedural irregularities in the tax assessment, specifically questioning whether a mandatory notice was issued before making the adjustment. The appellate authority was directed to ascertain the factual circumstances, particularly examining whether the absence of a show cause notice renders the tax adjustment invalid. The assessee's appeal was allowed for statistical purposes, with instructions to comprehensively review the procedural compliance and potential exemption allowability based on the audit report filing.
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