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2022 (6) TMI 1378 - AT - Income TaxAssessment u/s 92CA(3A) r.w.s. 153 - time limit for passing the transfer pricing order - HELD THAT:- Since the order passed by the TPO u/s 92CA of the I.T.Act is beyond the period of limitation and bad in law, the addition in respect of international taxation (TP adjustments) stands quashed. Therefore, grounds on merits on TP adjustments, both in assessee’s and revenue’s appeals are not adjudicated. Foreign tax credit claimed - HELD THAT:- We restore the matter to the A.O. for de novo consideration. A.O. is directed to compute foreign tax credit that is due to the assessee as per law after affording a reasonable opportunity of hearing to the assessee - Grounds allowed for statistical purposes. Computation of deduction u/s 10A - CIT(A) had directed the A.O. to reduce the impugned expenses from both the export turnover as well as from the total turnover while computing the deduction u/s 10A - HELD THAT:- The directions of the CIT(A) is in accordance with the judgment of HCL Technologies Ltd. [2018 (5) TMI 357 - SUPREME COURT] - Therefore, we see no reason to interfere with the order of the CIT(A) on this issue. It is ordered accordingly.
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