Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
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.
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