Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
HC held that the Assessing Officer (AO) erroneously disallowed ESI and EPF contributions under Section 143(1)(a), given the pendency of a Supreme Court matter regarding delayed deposit treatment. The legal issue was unresolved at the time of assessment, and subsequent SC judgment in Checkmate Services clarified the position. The ITAT's reliance on a previous HC order was deemed inappropriate. The prima facie disallowance of contributions under Section 36(1)(va) was set aside, with the decision rendered against the Revenue, mandating reconsideration under Section 143(3) of the Income Tax Act.
HC held that the Assessing Officer (AO) erroneously disallowed ESI and EPF contributions under Section 143(1)(a), given the pendency of a Supreme Court matter regarding delayed deposit treatment. The legal issue was unresolved at the time of assessment, and subsequent SC judgment in Checkmate Services clarified the position. The ITAT's reliance on a previous HC order was deemed inappropriate. The prima facie disallowance of contributions under Section 36(1)(va) was set aside, with the decision rendered against the Revenue, mandating reconsideration under Section 143(3) of the Income Tax Act.
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