2011 (8) TMI 1391 - AT - Income Tax

Summary

The ITAT Delhi, in appeal arising under sections 143(3) read with 144C of the Income-tax Act, addressed issues relating to transfer pricing and disallowance of provision for doubtful debts. The DRP had upheld the TPO's determination of Arm's Length Price (ALP) for international transactions, including applying a 10% CUP interest rate on loans to the assessee's AE, finding the TPO's approach reasonable. Regarding the disallowance of Rs. 21,48,564/- provision for doubtful debts under section 115JB (as amended by Finance Act, 2009), the Assessing Officer's view was affirmed. Both parties agreed that the DRP's order was summary and incomplete; accordingly, the ITAT restored the matter to the DRP for a fresh, speaking order under section 144C, directing it to address all objections after hearing the assessee, preferably within one year. The appeal was allowed for statistical purposes.