ITAT disallows grossing up of TDS deducted on interest paid to AE

Lite-on Mobile India Pvt. Ltd. Vs DCIT (ITAT Chennai) Facts- TPO in respect of procurement of management services determined NIL arm’s length price by holding that the assessee didn’t bring any evidence on record to suggest that it was in need for services for which it has paid to its AEs. Further, assessee has availed ECB loan from the related parties and paid interest. Assessee grossed up interest payment for TDS portion. TPO has disallowed grossing up of TDS deducted stating that the same is not allowed as deduction u/s 40A(2). Conclusion- We are of considered view that the assessee has...