https://www.taxtmi.com/highlights?id=94624 ITAT upheld the order of the CIT(A) allowing deduction u/s 80IA to the assessee-company and dismissing the Revenue's appeal. The Tribunal found that the civil works of the APSIDC Choutupalli lift irrigation project had been sub-contracted on a back-to-back basis to AE "MEIL", with the assessee consciously retaining only 2% of the contract value, despite being eligible for deduction u/s 80IA. Comparative profit margins demonstrated that related party transactions yielded a lower margin than unrelated party transactions, negating the allegation of profit inflation. ITAT held there was no evidence of under-billing or involvement in civil construction by the assessee, rendering the TP/assessment additions unsustainable. en-us Sat, 29 Nov 2025 07:57:26 +0530 Sat, 29 Nov 2025 07:57:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=94624 ITAT upheld the order of the CIT(A) allowing deduction u/s 80IA to the assessee-company and dismissing the Revenue's appeal. The Tribunal found that the civil works of the APSIDC Choutupalli lift irrigation project had been sub-contracted on a back-to-back basis to AE "MEIL", with the assessee consciously retaining only 2% of the contract value, despite being eligible for deduction u/s 80IA. Comparative profit margins demonstrated that related party transactions yielded a lower margin than unrelated party transactions, negating the allegation of profit inflation. ITAT held there was no evidence of under-billing or involvement in civil construction by the assessee, rendering the TP/assessment additions unsustainable. Highlights Income Tax Sat, 29 Nov 2025 07:57:26 +0530 https://www.taxtmi.com/highlights?id=94624