NO TP adjustment for expense already disallowed by Assessee

3M India Limited Vs CIT (LTU) (ITAT Bangalore) A perusal of the same would show that the assessee is making year end provision every year. The provision made in one year is reversed in the succeeding year. There is no dispute that the assessee has voluntarily disallowed the year end provision u/s 40(a), since no tax was deducted at source from the provision for Administrative and management support services made by the assessee. Under accounting principles also, when the actual payment is fully debited to the Expenditure account, the provision made in the preceding year shall be credited, so t...