2026 (2) TMI 1241

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....: Shri Sher Singh, CIT-D.R. ORDER PER SUCHITRA KAMBLE, JUDICIAL MEMBER: This is an appeal filed against the order dated 17-07- 2025 passed by CIT(A), Ahmedabad-13 for assessment year 2015-16. 2. The grounds of appeal are as under:- "(1) Whether on the facts and in circumstances of the case and in law, the Ld.CIT(A) was justified in deleting the transfer pricing adjustment by h....

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.... for the relevant year? (iv) The appellant craves leaves to add, modify, amend or alter any grounds of appeal at the time of, or before, the hearing of appeal." 3. The assessee is engaged in the business of manufacturing of sale of parecetamoal. The return of income was filed on 28- 11-2016 declaring total income of Rs. 13,41,14,490/- and book profit u/s. 115JB of the Act at Rs. 12,97,....

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....hems Ltd., it was found that the assessee company paid commission of Rs. 58,20,000/- instead of Rs. 31,01,136/- mentioned in the show cause notice. Thus, the contention of the assessee that the expenditure to that extent is allowable u/s. 37 as the TDS has been deducted on the commission payments was rejected by the A.O. The A.O. made the addition of Rs. 58,20,000/- for bogus commission. The A.O. ....

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.... takes effect only from 01- 04-2017 and applies prospectively to assessment year 2017-18 and subsequent years. The ld. D.R. further submitted that the CIT(A) was not justified in granting the relief solely without examining the merits of the ALP determination made by the TPO in accordance with the provisions applicable for the relevant year. 6. The ld. A.R. relied upon the assessment order and ....