https://www.taxtmi.com/highlights?id=93032 The ITAT upheld that a unilateral APA, covering AYs 2016-17 to 2020-21 and rolled back to AYs 2012-13 to 2015-16, applies to AY 2013-14 for the issue of reimbursement of AMP expenses; accordingly, appeals of the assessee and revenue on that issue were dismissed. On alleged TDS defaults under s.195 and consequent disallowance u/s 40(a)(i) for payments to non-residents, the ITAT found material facts regarding the nature of services, cost-plus markup and the "make available" contention were not on record; the claims warranted re-verification. The ITAT set aside the AO's and CIT(A)'s orders and remitted the matter to the AO for fresh adjudication in accordance with law. en-us Fri, 03 Oct 2025 08:30:38 +0530 Fri, 03 Oct 2025 08:30:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=93032 The ITAT upheld that a unilateral APA, covering AYs 2016-17 to 2020-21 and rolled back to AYs 2012-13 to 2015-16, applies to AY 2013-14 for the issue of reimbursement of AMP expenses; accordingly, appeals of the assessee and revenue on that issue were dismissed. On alleged TDS defaults under s.195 and consequent disallowance u/s 40(a)(i) for payments to non-residents, the ITAT found material facts regarding the nature of services, cost-plus markup and the "make available" contention were not on record; the claims warranted re-verification. The ITAT set aside the AO's and CIT(A)'s orders and remitted the matter to the AO for fresh adjudication in accordance with law. Highlights Income Tax Fri, 03 Oct 2025 08:30:38 +0530 https://www.taxtmi.com/highlights?id=93032