https://www.taxtmi.com/caselaws?id=451161 The ITAT Delhi restored the TP adjustment matter to the AO for fresh consideration after the assessee filed a modified return following a bilateral APA between India and USA covering the assessment year. The tribunal directed the AO to decide the issue afresh considering the APA provisions after providing adequate hearing opportunity. Regarding foreign tax credit, the tribunal noted favorable HC decisions supporting the assessee's position. For TDS credit shortfall, the matter was remanded to the AO for verification and proper credit allowance per legal provisions. en-us Mon, 11 Mar 2024 00:00:00 +0530 Thu, 21 Mar 2024 07:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=451161 The ITAT Delhi restored the TP adjustment matter to the AO for fresh consideration after the assessee filed a modified return following a bilateral APA between India and USA covering the assessment year. The tribunal directed the AO to decide the issue afresh considering the APA provisions after providing adequate hearing opportunity. Regarding foreign tax credit, the tribunal noted favorable HC decisions supporting the assessee's position. For TDS credit shortfall, the matter was remanded to the AO for verification and proper credit allowance per legal provisions. Case-Laws Income Tax Mon, 11 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=451161