Held that the issue relating to transfer pricing adjustment made by the Transfer Pricing Officer on receipt of guarantee fees by the assessee from its associated enterprises had been deleted by the Tribunal. Capitalisation of Foreign Exchange fluctuation loss on long-term foreign currency Loan taken for capital expenditure. Revision is not valid.
TCG Lifesciences Pvt. Ltd. v. PCIT (2022)100 ITR 52 (SN)(Kol.) (Trib)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Transfer Pricing adjustment-Addition was deleted by Tribunal-Capitalisation of Foreign Exchange fluctuation loss on long-term foreign currency Loan taken for capital expenditure-Revision is not valid [S.43A 92C 143(3)]