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2023 (12) TMI 332 - ITAT HYDERABADTP Adjustment - Interest on outstanding receivables due from AEs - Whether outstanding receivables is not covered in the definition of international transaction as defined u/s 92B? - HELD THAT:- In the present case, DRP has not considered the submissions of the assessee on trade receivables and it is categorically mentioned that the period granted for furnishing the details was too short and therefore, there was violation of principles of natural justice and thereafter, DRP has directed the TPO to grant one more opportunity to the assessee to explain and decide the issue. TPO has passed the order pursuant to the direction of DRP on 22.06.2022 and thereafter, the AO has passed the order on 30.06.2022. In our view and in the light of the submissions made before us by AR that sufficient opportunity was not granted by the lower authorities, we are of the opinion that one more opportunity is required to be given to the assessee to explain its case before the TPO. We deem it appropriate to remand back the matter to the file of AO / TPO for passing a fresh order. Appeal of the assessee is allowed for statistical purposes.
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