Unilateral APA applied to AY2013-14 for AMP reimbursement; TDS under s.195 and disallowance u/s 40(a)(i) remitted for re-verification

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....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.....