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2017 (10) TMI 232 - AT - Income TaxAddition pertaining to recharge paid to the AE - TPA - Held that:- We found that in the A.Y.2011-12, exactly similar ground was raised by the assessee before Tribunal with regard to addition of ₹ 2,58,13,084/- on account of recharge paid to the AE. After discussing the issue in great detail, the Tribunal have deleted the addition. Exactly, similar ground has been raised in this year also. As the facts and circumstances during the year under consideration are same, respectfully following the order of the Tribunal in assessee’s own case for immediately preceding year, we delete the addition so made by the AO. Interest u/s.234A - Held that:- This issue is squarely covered by the decision of Delhi High Court in case of Dr. Prannoy Roy [2001 (12) TMI 68 - DELHI High Court] wherein Hon’ble High Court has held that no interest u/s.234A is payable in respect of amount of self assessment taxes which has been deposited prior to the due date of filing of the return. Accordingly, we direct the AO to recompute the interest u/s.234A by considering self assessment tax paid before filing of the return. We direct accordingly.
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