https://www.taxtmi.com/caselaws?id=445860 ITAT Chandigarh held that transfer pricing adjustments under section 92CA read with section 80-IA(8)/80IC cannot result in addition to returned income when the assessee has not claimed deduction under section 80IC for the current year due to accumulated losses. The TPO's adjustment, though valid for benchmarking inter-unit transactions of Unit V eligible for section 80IC deduction, would only reduce current year profits and increase carried forward losses. Since no profits were available after setting off past losses and no section 80IC claim was made, the adjustment cannot enhance taxable income. The addition was directed to be deleted. en-us Tue, 05 Sep 2023 00:00:00 +0530 Tue, 21 Nov 2023 11:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445860 ITAT Chandigarh held that transfer pricing adjustments under section 92CA read with section 80-IA(8)/80IC cannot result in addition to returned income when the assessee has not claimed deduction under section 80IC for the current year due to accumulated losses. The TPO's adjustment, though valid for benchmarking inter-unit transactions of Unit V eligible for section 80IC deduction, would only reduce current year profits and increase carried forward losses. Since no profits were available after setting off past losses and no section 80IC claim was made, the adjustment cannot enhance taxable income. The addition was directed to be deleted. Case-Laws Income Tax Tue, 05 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445860