Section 10A and related deductions: Tribunal rejects separate-undertaking claim, but allows loss set-off, ESOP cost and foreign tax credit in principl...
Additions - under pricing to sister concern - This action of the A.O. is unjustified. Hence, the addition on account of underpricing was not warranted. The assessing officer missed the vital point that income was below taxable limit after b/f losses were set off during the current year. Moreover, there was no finding by the lower authorities that sister concerns benefited in any manner.
Additions - under pricing to sister concern - This action of the A.O. is unjustified. Hence, the addition on account of underpricing was not warranted. The assessing officer missed the vital point that income was below taxable limit after b/f losses were set off during the current year. Moreover, there was no finding by the lower authorities that sister concerns benefited in any manner.
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