https://www.taxtmi.com/caselaws?id=779298 ITAT held the unilateral APA covering AYs 2016-17 to 2020-21 and rolled back to AYs 2012-13 to 2015-16 applies to AY 2013-14 on the issue of reimbursement of AMP expenses; appeals on that issue were dismissed. On TDS u/s 195 and disallowance u/s 40(a)(i) for payments to non-residents, the tribunal found material facts about nature of services, cost-plus markup and "make available" not on record; it set aside the AO and CIT(A) orders and remanded the matter to the AO for fresh adjudication and verification. en-us Fri, 26 Sep 2025 00:00:00 +0530 Fri, 03 Oct 2025 08:30:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779298 ITAT held the unilateral APA covering AYs 2016-17 to 2020-21 and rolled back to AYs 2012-13 to 2015-16 applies to AY 2013-14 on the issue of reimbursement of AMP expenses; appeals on that issue were dismissed. On TDS u/s 195 and disallowance u/s 40(a)(i) for payments to non-residents, the tribunal found material facts about nature of services, cost-plus markup and "make available" not on record; it set aside the AO and CIT(A) orders and remanded the matter to the AO for fresh adjudication and verification. Case-Laws Income Tax Fri, 26 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779298