ITAT Restores Fair Benchmarking on TP Interest & Grants Corporate Tax Reliefs

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...