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Income Tax - Highlights / Catch Notes

Home Highlights January 2025 Year 2025 This

The ITAT held that protective additions made by the AO ...


Protective additions on IT fees, commission disallowed post MAP resolution.

January 21, 2025

Case Laws     Income Tax     AT

The ITAT held that protective additions made by the AO concerning payments for information & technology fees and commission on sales were not tenable. Since the assessee had already settled these disputes with the competent authority under MAP and accepted the adjustments made by the TPO, no further disallowance u/s 37 was required to be sustained on a protective basis for the relevant assessment years. The assessee's appeals were allowed.

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