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The ITAT allowed the first ground in favor of the revenue pursuant to the assessee's concession and the revenue's non-objection, resulting in the appellate tribunal upholding the TP adjustment for notional interest on outstanding receivables from an associated enterprise without adjudicating the substantive merits. Conversely, the ITAT set aside the disallowance under section 14A read with Rule 8D, restoring the Commissioner (Appeals) order in favour of the assessee on the basis that no exempt income was earned and therefore no s.14A disallowance was warranted, following precedential treatment of the assessee's earlier assessment year.
The ITAT allowed the first ground in favor of the revenue pursuant to the assessee's concession and the revenue's non-objection, resulting in the appellate tribunal upholding the TP adjustment for notional interest on outstanding receivables from an associated enterprise without adjudicating the substantive merits. Conversely, the ITAT set aside the disallowance under section 14A read with Rule 8D, restoring the Commissioner (Appeals) order in favour of the assessee on the basis that no exempt income was earned and therefore no s.14A disallowance was warranted, following precedential treatment of the assessee's earlier assessment year.
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