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2018 (7) TMI 2080 - HC - Income TaxMarket risk adjustment - Rule 10B (3) of the Income-tax Rules, 1962 provides for an adjustment for risk Differential - HELD THAT:- No substantial question of law arising in the present case as the learned Tribunal has given sufficient reasons for not allowing any risk adjustment following its earlier view in the case of Zyme Solutions Pvt. Ltd. vs. ITO [2016 (6) TMI 1375 - ITAT BANGALORE] quoted in the said order. ITAT justification in not following Section 253(4) read with Rule 22 of the Income-tax (Appellate Tribunal) Rules, 1963 - HELD THAT:- We do not find any force in the said submission of the learned counsel for the appellant assessee. If the cross-objection filed by the appellant assessee in the appeal is registered and not decided by the learned Tribunal, the appellant-assessee itself may file proper Miscellaneous application before the learned Tribunal.
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