Held, that the matter was remanded to the CIT(A) for adjudication on the merits after ascertaining the facts and applicable position of law thereon. The CIT (A) shall also take appropriate measures to direct the Assessing Officer to carry out the rectification of the adjustments made in accordance with law giving reasonable opportunity of hearing to the assessee. (AY. 2019-20)
CanLah Investments Pte. Ltd. v. Asst. CIT CPC (2023)101 ITR 9 (SN.)(Delhi) (Trib)
S. 6(3) : Residence in India-Company –Prima faice adjustments-Derivative Income claimed as exempt as per DTAA between India and Singapore-CIT(A) denied examining the issue on merits on the ground that proper medium of communication not used-Matter remanded for fresh adjudication on merits-DTAA-India-Singapore. [Art. 13 (5)]