Protective adjustment- ITAT directs AO to decide in the light of MAP resolution

BT Global Communications India Pvt. Ltd.  Vs. Addl. CIT   (Delhi ITAT) The only issue to be decided in the present appeal relates to protective adjustment on account of business restructuring that has taken place in assessment year 2010-11. We find that TPO/DRP have made adjustment on substantive basis in assessment year 2010-11. However, since the proceedings in assessment year 2010-11 were subjudice, protective adjustment was made in the impugned assessment order making an addition of Rs. 100,69,37,657/- which is in line with similar addition for assessment year 2011-12, 2012-13 and 2014-1...