https://www.taxtmi.com/caselaws?id=799597 Material additional evidence concerning the formation and operation of a special economic zone undertaking was admitted for fresh consideration of the deduction claim and transfer-pricing adjustment. Its relevance lay in determining whether the undertaking was newly established or resulted from splitting up or reconstruction of an existing business, and in examining interconnected functional and procurement arrangements affecting arm's-length determination and eligible profits. Fresh adjudication must consider the additional and relevant material after providing a reasonable opportunity of hearing; no merits determination was made on either claim. en-us Thu, 27 Aug 2026 00:00:00 +0530 Thu, 24 Sep 2026 08:27:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799597 Material additional evidence concerning the formation and operation of a special economic zone undertaking was admitted for fresh consideration of the deduction claim and transfer-pricing adjustment. Its relevance lay in determining whether the undertaking was newly established or resulted from splitting up or reconstruction of an existing business, and in examining interconnected functional and procurement arrangements affecting arm's-length determination and eligible profits. Fresh adjudication must consider the additional and relevant material after providing a reasonable opportunity of hearing; no merits determination was made on either claim. Case-Laws Income Tax Thu, 27 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799597