https://www.taxtmi.com/caselaws?id=778622 ITAT (DELHI - AT) upheld CIT(A)'s reliefs and dismissed revenue's contentions. The Tribunal confirmed deletion of the TPO's markup on head-office allocations under s.80IC as covered by prior tribunal orders; disallowed additions under ss.69A and 69C for lack of adverse material and proper nexus; struck down the ad-hoc 20% disallowance as conjectural; and rejected reliance on non-compliance of s.133(6) notices by some suppliers as proof of bogus transactions. It further held that where tax under MAT (s.115JB) exceeds liability under s.115BBE, s.115JB governs, a position later accepted by the AO on reassessment. en-us Fri, 17 Jan 2025 00:00:00 +0530 Fri, 19 Sep 2025 08:33:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778622 ITAT (DELHI - AT) upheld CIT(A)'s reliefs and dismissed revenue's contentions. The Tribunal confirmed deletion of the TPO's markup on head-office allocations under s.80IC as covered by prior tribunal orders; disallowed additions under ss.69A and 69C for lack of adverse material and proper nexus; struck down the ad-hoc 20% disallowance as conjectural; and rejected reliance on non-compliance of s.133(6) notices by some suppliers as proof of bogus transactions. It further held that where tax under MAT (s.115JB) exceeds liability under s.115BBE, s.115JB governs, a position later accepted by the AO on reassessment. Case-Laws Income Tax Fri, 17 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778622