ITAT Deletes Software Cost Mark-Up Addition Holding Pure Reimbursement Is Not Profit-Making Service

SRF Limited Vs ACIT (ITAT Delhi) In a detailed ruling concerning Assessment Year 2020-21, the Income Tax Appellate Tribunal (ITAT), Delhi, partly allowed the assessee’s appeal against the assessment order passed under Sections 143(3), 144C(3), and 144B of the Income Tax Act. The dispute involved multiple transfer pricing adjustments, disallowances, and levy of interest. The assessee had originally filed a return declaring income of Rs. 194.99 crore. The case was selected for complete scrutiny on various issues including transfer pricing, stock valuation, deductions under Section 80-IA, expen...