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    <title>2026 (1) TMI 1632 - ITAT MUMBAI</title>
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    <description>A transfer pricing adjustment based on DRI-triggered over-invoicing information could not survive once the customs proceedings had exonerated the assessee and that finding was upheld in appeal, because the foundation for reopening and addition had disappeared. The Tribunal therefore upheld deletion of the adjustment and dismissed the Revenue&#039;s appeal. Separately, the delay in filing the cross-objection was condoned on the basis of an affidavit and a bona fide medical explanation, but the cross-objection itself was treated as infructuous after the merits were decided.</description>
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      <title>2026 (1) TMI 1632 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=469081</link>
      <description>A transfer pricing adjustment based on DRI-triggered over-invoicing information could not survive once the customs proceedings had exonerated the assessee and that finding was upheld in appeal, because the foundation for reopening and addition had disappeared. The Tribunal therefore upheld deletion of the adjustment and dismissed the Revenue&#039;s appeal. Separately, the delay in filing the cross-objection was condoned on the basis of an affidavit and a bona fide medical explanation, but the cross-objection itself was treated as infructuous after the merits were decided.</description>
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