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2024 (1) TMI 494 - AT - Income TaxTP Adjustment - assessee prayed for admission of additional evidences and pleaded that the matter may be remanded to AO/TPO for fresh consideration - HELD THAT:- As in similar facts and circumstances in assessee’s own case for AY 2004-05 [2023 (12) TMI 406 - ITAT DELHI], the ITAT restored the matter on this issue to the authorities below - Accordingly, the impugned final assessment order is set aside and the AO/TPO is directed to accept the fresh evidences and report of the assessee for the purpose of Section 92C of the Income-tax Act, 1961 (for short 'the Act') read with Rule 10B of the Income tax Rules, 1962 and after giving further opportunity to the assessee pass fresh order. The assessee will be at liberty to raise further incidental issues afresh before the TPO/AO. Valuation and depreciation of goodwill - When the transfer pricing issue is being remitted in its entirety along with additional evidences, it will be appropriate that these issues are also remitted to AO/TPO. The AO/TPO shall consider the issues afresh after giving assessee proper opportunity of being heard. Both the appeals filed by the assessee are allowed for statistical purposes.
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