https://www.taxtmi.com/caselaws?id=312299 The ITAT Delhi held that the assessee was entitled to deduction under Section 80IA(4) for infrastructure projects executed for DFCCIL, IRCON, and PGCIL, as these entities were public sector undertakings formed under government ministries, fulfilling statutory body requirements. The tribunal found the assessee was a developer, not merely a contractor, based on risk allocation and project responsibilities. Transfer pricing adjustments regarding interest receivables from associated enterprises and loan interest from an individual were remanded to AO/TPO for fresh determination with proper benchmarking. Disallowance of late PF deposits was upheld following SC precedent in Checkmate Services. The retention money disallowance issue was remanded for verification against the revised return. en-us Wed, 30 Nov 2022 00:00:00 +0530 Sat, 10 Feb 2024 16:00:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312299 The ITAT Delhi held that the assessee was entitled to deduction under Section 80IA(4) for infrastructure projects executed for DFCCIL, IRCON, and PGCIL, as these entities were public sector undertakings formed under government ministries, fulfilling statutory body requirements. The tribunal found the assessee was a developer, not merely a contractor, based on risk allocation and project responsibilities. Transfer pricing adjustments regarding interest receivables from associated enterprises and loan interest from an individual were remanded to AO/TPO for fresh determination with proper benchmarking. Disallowance of late PF deposits was upheld following SC precedent in Checkmate Services. The retention money disallowance issue was remanded for verification against the revised return. Case-Laws Income Tax Wed, 30 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312299