2020 (2) TMI 1738 - SCH - Income Tax

TP Adjustment - exemption u/s 10A - Treatment to interest income - ITAT Directing to adopt 16.63% Arm s Length margin for transaction relating to non US entities based on MAP concluded with US Tax Authorities ITAT justification in holding that exemption u/s 10A is allowable prior to the setting off of brought forward losses and unabsorbed depreciation. ITAT justification in holding interest income as business income HC confirmed ITAT justification HELD THAT - The special leave petition is dismissed.

Summary

The Supreme Court of India, with Hon'ble Mr. Justice Ashok Bhushan and Hon'ble Mr. Justice M.R. Shah presiding, heard the case with Mr. K.M. Nataraj, ASG, Ms. Swarupama Chaturvedi, Adv., Mr. V.D. Sundriyal, Adv., and Mrs. Anil Katiyar, AOR representing the Petitioner. The Respondent was not represented. The Court condoned the delay and dismissed the special leave petition, disposing of any pending applications.