TaxTMI 
TaxTMI 
2026 (9) TMI 602
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....e Assessee : Ms. Priyanka Jain a/w Ms. Sofia Shanmugam, Ld. A.Rs. For the Revenue : Shri Saurabh Deshpande, Ld. CIT D.R. ORDER PER: NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER: This appeal has been preferred by the Assessee against the final assessment order dated 28.01.2026, impugned herein, passed by the AO u/s 143(3) r.w.s. 144C(13) and 144B of the Income-tax Act, 1961 (in short, "the ....
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.... expenditure of Rs. 26,81,32,346/-. 4. The TPO, vide order dated 27.01.2025 passed u/s 92CA(3) of the Act, determined the arm's length price of the said services at Nil, principally on the ground that the Assessee failed to establish actual rendition and receipt of services, costs incurred by the associated enterprise and corresponding benefit. Accordingly, an adjustment of Rs. 26,81,32,346/- w....
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....charges due to the continued losses of the Assessee and, consequently, the liability was written back and offered to tax in A.Y. 2023-24. Reference was made to the relevant financial statements, computation of income, Form No. 3CEB, waiver letter and the assessment record for that year. It was further submitted that the transaction was examined in A.Y. 2023-24 and no corresponding transfer-pricing....
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....tood offered to tax in the subsequent year. 10. In these circumstances, the Revenue's alternative plea for restoring the matter to the TPO cannot be accepted. No fresh determination of the arm's length price is required for deciding the limited question of duplication of taxation. The issue now survives only to verify whether the identical amount has actually been offered to and retained in tax....