2025 (8) TMI 832

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....bul Singhal, CA For the Revenue : Ms. Indu Bala Saini, Sr. DR ORDER PER M. BALAGANESH, A. M.: 1. By virtue of this miscellaneous application, the revenue seeks to recall the order passed by the tribunal in ITA No. 590/Del/2021 dated 20.07.2023 for Assessment Year 2016-17 wherein it was held that transfer pricing adjustment of Rs.91,04,673/- and further addition of Rs. 27,31,402/-, whic....

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.... MA application states that the transaction entered by the assessee falls within the ambit of Section 92BA(v) of the Act. We find that the transfer pricing adjustment has been made only in respect of transfer of some finished goods from non-eligible unit to eligible unit in the context of provisions of section 80IC of the Act. This as rightly pointed out by the revenue falls in section 92BA(v) of ....