Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
ITAT upheld the order of the CIT(A) allowing deduction u/s 80IA to the assessee-company and dismissing the Revenue's appeal. The Tribunal found that the civil works of the APSIDC Choutupalli lift irrigation project had been sub-contracted on a back-to-back basis to AE "MEIL", with the assessee consciously retaining only 2% of the contract value, despite being eligible for deduction u/s 80IA. Comparative profit margins demonstrated that related party transactions yielded a lower margin than unrelated party transactions, negating the allegation of profit inflation. ITAT held there was no evidence of under-billing or involvement in civil construction by the assessee, rendering the TP/assessment additions unsustainable.
ITAT upheld the order of the CIT(A) allowing deduction u/s 80IA to the assessee-company and dismissing the Revenue's appeal. The Tribunal found that the civil works of the APSIDC Choutupalli lift irrigation project had been sub-contracted on a back-to-back basis to AE "MEIL", with the assessee consciously retaining only 2% of the contract value, despite being eligible for deduction u/s 80IA. Comparative profit margins demonstrated that related party transactions yielded a lower margin than unrelated party transactions, negating the allegation of profit inflation. ITAT held there was no evidence of under-billing or involvement in civil construction by the assessee, rendering the TP/assessment additions unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
