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2020 (11) TMI 1082 - AT - Income TaxTP Adjustment - determination for ALP for provision of SWD services - HELD THAT:- Companies functionally dissimilar with that of assessee need to be deselected from final list. Addition u/s 40A(7) - assessee company had failed to communicate the changes/ alterations made to the fund, as required under Rule 4(2) of the Fourth Schedule of IT Act and the contribution to fund is only a provision and not an actual expense under the purview of section 37(1) - HELD THAT:- Identical issue arose in assessee’s own case for AY 2010-11 [2017 (11) TMI 1861 - ITAT BANGALORE] as upheld the action of the DRP in deleting the addition made by AO.
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