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2026 (9) TMI 848

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....T MEMBER For the Appellant : Shri Nageswar Rao, Adv. & Shri Pratik Rath, Adv. For the Respondent : Shri Mahesh Kumar, CIT DR ORDER PER SANJAY AWASTHI, ACCOUNTANT MEMBER: 1. This appeal arises from order passed by AO-NFAC, dated 26.07.2024, u/s. 143(3) read with section 144C(13) r.w.s. 144B of the Income Tax Act, 1961 (hereafter as "the Act"). 1.1 In this case, following the DRP's....

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.... Please find attached order giving effect passed by Ld. Transfer Pricing Officer pursuant to remand direction of Hon'ble ITAT in relating to AY 2021-22 [Annexure A] granting complete relief involving identical issue. As said Order giving effect was received post hearing of Appeal No. ITA 4410/DEL/2024, on 10.08.2026 this may kindly be taken on record and placed before Hon'ble Memb....

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....back to the file of the TPO with direction to verify the additional evidences placed on record by the assessee and redo the TP study, a fresh reference was received in this case from the JAO. Consequently, in pursuance to fresh set aside proceedings in this case, notice dated 31.07.2026 was issued giving an opportunity to the assessee to file its submission. In response to said notice, the assesse....