Transfer Pricing Method for 15-Year Unsecured Loan Invalid; Section 80IAB Deduction Denied for Unclaimed Income Sources

ITAT upheld DRP's decision regarding jurisdiction on s.80IAB deduction, confirming DRP lacked authority where no variation was proposed in Draft Assessment Order. Assessee's claim for s.80IAB deduction on Income from Other Sources and Short-Term Capital Gains was rejected as it wasn't claimed in original return or Form 10CCB, violating s.80A(5) and s.80AC requirements. On Transfer Pricing, ITAT found both assessee's "other method" benchmarking and TPO's SBI overdraft comparison inappropriate for 15-year unsecured loan transaction. Matter remanded to TPO/AO for fresh benchmarking analysis with directions to provide hearing opportunity to assessee. .....

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