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ITAT Restores Fair Benchmarking on TP Interest & Grants Corporate Tax Reliefs
Case Law Details
- Case Name
- Lowe’s Services India Pvt. Ltd. Vs DCIT (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2020-21
- Courts
- All ITAT, ITAT Bangalore
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Lowe’s Services India Pvt. Ltd. Vs DCIT (ITAT Bangalore)
Background:
Lowe’s Services India Pvt. Ltd., a subsidiary of Lowe’s US, provides software development (SWD) & ITeS-Business Support Services to its AE. For AY 2020-21, return was filed at ₹78.61 Cr. The AO/TPO proposed TP adjustments of ₹50.69 Cr, disallowances u/s 36(1)(va) (₹1.32 lakh) & u/s 80G (₹76.48 lakh). DRP deleted major TP adjustments but sustained interest on receivables & denied 80G deduction. Final assessed income: ₹81.69 Cr. Assessee appealed.
Key Issues & Findings:
TP Adjustment – Interest...
Author Info
