Protective Addition Unsustainable if Substantial Addition is Confirmed or Settled: ITAT Bangalore

LM Wind Power Blades (India) Pvt. Ltd. Vs DCIT (ITAT Bangalore) The Income Tax Appellate Tribunal (ITAT), Bangalore, has ruled in favor of LM Wind Power Blades (India) Pvt. Ltd., deleting the protective addition made by the Assessing Officer (AO) concerning information & technology fees and commission payments. The case pertains to assessment years 2010-11, 2011-12, and 2013-14, where the Transfer Pricing Officer (TPO) had already made adjustments under Section 92CA of the Income Tax Act, 1961, on payments to associated enterprises (AEs). The Dispute Resolution Panel (DRP) later reduced th...