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    <title>2025 (7) TMI 1032 - ITAT KOLKATA</title>
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    <description>The ITAT Kolkata directed deletion of an addition under section 69 due to lack of discussion in the AO&#039;s order, accepting the DR&#039;s argument that it was made due to oversight. Regarding TP adjustment, the matter was remanded to the TPO to recalculate the Arm&#039;s Length PLI considering an agreement dated 24.03.2025 between the assessee and CBDT, despite the impugned order predating this agreement. The AO was directed to give effect to the TPO&#039;s subsequent working. For interest under section 234A, the issue was remanded to the AO to recalculate after considering the assessee&#039;s submissions regarding CBDT&#039;s extension of return filing date, as there was no proper discussion in the original order and interest appeared to be charged only in the computation part.</description>
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    <pubDate>Mon, 23 Jun 2025 00:00:00 +0530</pubDate>
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      <title>2025 (7) TMI 1032 - ITAT KOLKATA</title>
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      <description>The ITAT Kolkata directed deletion of an addition under section 69 due to lack of discussion in the AO&#039;s order, accepting the DR&#039;s argument that it was made due to oversight. Regarding TP adjustment, the matter was remanded to the TPO to recalculate the Arm&#039;s Length PLI considering an agreement dated 24.03.2025 between the assessee and CBDT, despite the impugned order predating this agreement. The AO was directed to give effect to the TPO&#039;s subsequent working. For interest under section 234A, the issue was remanded to the AO to recalculate after considering the assessee&#039;s submissions regarding CBDT&#039;s extension of return filing date, as there was no proper discussion in the original order and interest appeared to be charged only in the computation part.</description>
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