https://www.taxtmi.com/caselaws?id=790721 The Assessing Officer could not sustain an addition under Section 40(a)(i) where the Dispute Resolution Panel had issued a binding direction not to make the addition unless the Department had filed an appeal against the Tribunal order. The record showed that no departmental appeal was pending, so the impugned demand was made in direct conflict with the directions issued under Section 144A. That addition was therefore set aside. The transfer pricing addition was left open for challenge in appeal. en-us Tue, 21 Apr 2026 00:00:00 +0530 Wed, 29 Apr 2026 08:16:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790721 The Assessing Officer could not sustain an addition under Section 40(a)(i) where the Dispute Resolution Panel had issued a binding direction not to make the addition unless the Department had filed an appeal against the Tribunal order. The record showed that no departmental appeal was pending, so the impugned demand was made in direct conflict with the directions issued under Section 144A. That addition was therefore set aside. The transfer pricing addition was left open for challenge in appeal. Case-Laws Income Tax Tue, 21 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790721