TP Adjustment Cannot Be Added to MAT Book Profits: ITAT Delhi

Innovative Textiles Limited Vs DCIT (ITAT Delhi) Assessee challenged assessment order framed u/s 143(3) r.w.s. 144C(13)/144B pursuant to DRP’s directions, wherein AO made transfer pricing adjustment of Rs.84,95,443/- on purchase of cotton from its AE & further added this adjustment to book profits u/s 115JB. Assessee argued that while TP adjustment in normal computation may be contested separately, adding such adjustment to book profit u/s 115JB was impermissible. Reliance was placed on SC in Apollo Tyres Ltd. 255 ITR 273 & ITAT Delhi ruling in Cash Edge India Pvt. Ltd. (ITA 64/Del/2...