Order Validity Challenged Over Section 144B Non-Compliance; TP Adjustments and Loss Set-Offs Addressed.

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....Validity of order passed by jurisdictional AO not in compliance with section 144B discussed; technical glitches faced by revenue leading to transfer by PCIT to jurisdictional AO not reflected on ITBA portal; circular dated 06.09.2021 and letter dated 01.08.2023 clarified order transfer with CBDT approval. TP adjustment - comparable selection - deselection of comparables for turnover exceeding 200 crores against assessee's 14.53 crores in ITeS segment. Deselection of Manipal Digital Systems Pvt. Ltd. for lacking segmental service details. Working capital adjustment allowed following Coordinate Bench decision in Huawei Technologies India case. Non-granting of set-off of brought forward losses against final adjustment erroneous; AO directed to grant set-off. ITAT = Appellate Tribunal.....