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    <title>2026 (2) TMI 687 - ITAT DELHI</title>
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    <description>Where the assessee had already disallowed and included interest paid to an associated enterprise in taxable income and paid tax, a further upward transfer pricing adjustment on the same interest was deleted because it would produce double taxation. The assessee was held entitled to the concessional tax rate despite delayed filing of Form 10-IC where the form and return were on record and extensions applied; delay treated as procedural. Interest under provisions for shortfall and deferment is to be recomputed: one on income as finally determined and the other on income declared in the return. Penalty proceedings were held premature.</description>
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    <pubDate>Fri, 16 Jan 2026 00:00:00 +0530</pubDate>
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      <title>2026 (2) TMI 687 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=786539</link>
      <description>Where the assessee had already disallowed and included interest paid to an associated enterprise in taxable income and paid tax, a further upward transfer pricing adjustment on the same interest was deleted because it would produce double taxation. The assessee was held entitled to the concessional tax rate despite delayed filing of Form 10-IC where the form and return were on record and extensions applied; delay treated as procedural. Interest under provisions for shortfall and deferment is to be recomputed: one on income as finally determined and the other on income declared in the return. Penalty proceedings were held premature.</description>
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      <pubDate>Fri, 16 Jan 2026 00:00:00 +0530</pubDate>
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