TP Adjustment Under 80IA(10) Dismissed for Lack of Evidence

DCIT Vs Koya and Company Construction Ltd. (ITAT Delhi)

TP Adjustment Under 80IA(10) Unsustainable: Delhi ITAT Upholds 2% Margin & Dismisses Revenue’s Appeal

Revenue challenged deletion of TP/80IA(10) adjustment of Rs.2,57,05,203 & deletion of ad-hoc disallowance of Rs.12,72,014. Assessee, engaged in turnkey pipeline & civil infrastructure contracts, had sub-contracted civil works of the APSIDC Choutupalli Lift Irrigation project to AE Megha Engineering & Infrastructure Ltd (MEIL) on a back-to-back basis, retaining only a 2% margin. TPO rejected entity-leve

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