ITAT Directs AO to Follow APA as Royalty Transaction Became Covered Under New Agreement

GIA India Laboratory Pvt. Ltd. Vs DCIT (ITAT Mumbai) The appeal concerned three principal issues: (i) a transfer pricing adjustment relating to royalty payments to an Associated Enterprise (AE), (ii) denial of deduction under Section 80G, and (iii) issues relating to grant of TDS credit, credit for taxes paid, and interest under Section 244A. Transfer Pricing Adjustment on Royalty Payment The Assessing Officer (AO), through a draft assessment order dated 25 September 2023 under Section 144C(1), made an upward adjustment of ₹66,96,52,179 to the appellant’s income in relation to royalty paid...