TP Adjustment - Disallowance on professional fee u/s 40A(2) and ...

Assessing Officer misapplies Section 40A(2), contradicts TPO's arm's length findings on professional fee expense disallowance.

April 20, 2021

Case Laws Income Tax AT

TP Adjustment - Disallowance on professional fee u/s 40A(2) and alternatively u/s 37 - the A.O. has erred in invoking the provisions of section 40A(2) of the I.T.Act to disallow the claim of expense as excessive and not legitimate to the business needs, especially in view of the fact that the TPO, in its transfer pricing orders for assessment years 2008-2009 and 2010-2011, had held the impugned transaction at arms length. - AT

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TP Adjustment - Disallowance on professional fee u/s 40A(2) and ...

Assessing Officer misapplies Section 40A(2), contradicts TPO's arm's length findings on professional fee expense disallowance.

April 20, 2021

Case Laws Income Tax AT

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