Double Taxation Bar Invoked to Delete Interest TP Adjustment: ITAT Delhi

Noida Towers Private Limited Vs Assessment Unit (ITAT Delhi) No Double Disallowance of Interest & Late Form 10-IC Not Fatal: ITAT Delhi Grants TP Relief and Concessional Tax Rate The Delhi ITAT partly allowed the assessee’s appeal, holding that once the entire interest paid on non-convertible debentures (NCDs) to the Associated Enterprise had already been suo motu disallowed under Section 94B and added back in the computation, any further transfer pricing adjustment on the same amount would amount to impermissible double taxation. Since the assessee had not claimed the interest as a dedu...