No TP Adjustment Allowed if Foreign LLC Income Was Already Taxed in India: ITAT Delhi

Elofic Industries Limited Vs ACIT (ITAT Delhi) The Delhi Income Tax Appellate Tribunal (ITAT) partly allowed the assessee’s appeal and deleted multiple transfer pricing and related adjustments made by the Assessing Officer (AO), Transfer Pricing Officer (TPO), and Dispute Resolution Panel (DRP). The assessee, engaged primarily in the manufacture of automotive filters, challenged transfer pricing adjustments relating to transactions with its associated enterprise, Elofic USA LLC, adjustments on overdue receivables, and reductions in deduction claimed under Section 80-IC. The Tribunal noted th...