Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
On TP adjustment relating to computation of operating margins of selected comparables, the directions were held non-speaking because the panel addressed only bank charges and failed to adjudicate specific objections on items such as treasury expenses and interest on working capital loans, violating section 144C(5)/(8) and principles of natural justice; the matter was remanded for verification from audited financials, fresh consideration of all objections, and recomputation of arm's length margin. On foreign exchange loss and related brokerage/commission, the disallowance was sustained on merits, but the AO was directed to verify the correct quantum of loss claimed versus disallowed. On section 40(a)(ia), the AO was directed to verify the claim of lower TDS based on certificate and pass orders accordingly, allowing the ground for statistical purposes. - ITAT
On TP adjustment relating to computation of operating margins of selected comparables, the directions were held non-speaking because the panel addressed only bank charges and failed to adjudicate specific objections on items such as treasury expenses and interest on working capital loans, violating section 144C(5)/(8) and principles of natural justice; the matter was remanded for verification from audited financials, fresh consideration of all objections, and recomputation of arm's length margin. On foreign exchange loss and related brokerage/commission, the disallowance was sustained on merits, but the AO was directed to verify the correct quantum of loss claimed versus disallowed. On section 40(a)(ia), the AO was directed to verify the claim of lower TDS based on certificate and pass orders accordingly, allowing the ground for statistical purposes. - ITAT
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