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2022 (5) TMI 1512 - AT - Income TaxSimultaneous addition u/s 40(a)(ia) and 92CA - amount pertaining to Intra Group Services - HELD THAT:- If the interpretation sought to be taken by the AO/CIT(A) is accepted in the instant situation, then the assessee would be fastened with the liability to pay taxes on the same amount twice within the same assessment year. In the instant case, once the amount pertaining to Intra Group Services has been disallowed u/s 40(a)(ia) and added back to the total income, disallowing the same by treating the ALP has Nil and adding the same again to the total income certainly leads to a situation of taxing the same amount twice. Revenue is hereby directed to allow depreciation @ 15% instead of 10%.
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