2021 (5) TMI 302

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... ORDER PER M. BALAGANESH (A.M): By virtue of this Miscellaneous Application, the Revenue seeks to recall the order passed by this Tribunal in ITA No.5841/Mum/2017 dated 21/08/2019 for the A.Y.2013-14. 2. We have heard rival submissions and perused the materials available on record. We find that the main grievance of the Revenue in the Miscellaneous Application is that the ld. Pr. Commi....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ad indeed dealt and adjudicated the grounds raised by the Revenue alongwith Form 36 in respect of transfer pricing adjustment on account of comfort guarantee. If the ld. AO in his wisdom chose not to raise the other grounds which have been approved by the ld. PCIT in his authorisation memo, it is an issue which had to be internally sorted out between the ld. AO and the ld. PCIT. No error whatsoeve....