NATEMS SOLAR POWER PRIVATE LIMITED ,HYDERABAD vs. INCOME TAX OFFICER, WARD 16(1), HYDERABAD

ITA 140/HYD/2024Status: DisposedITAT Hyderabad14 May 2025AY 2020-2142 pages
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What did the Tribunal hold?

The Tribunal held that since the assessee did not claim any deduction for interest paid on supplier's credit and had no revenue from operations, the AO could not make any addition based on Transfer Pricing adjustment for this item. Consequently, the addition of Rs. 2,52,454/- was vacated.

What were the facts?

The assessee company, engaged in solar energy, filed its return for AY 2020-21. The case was selected for scrutiny, and the Assessing Officer (AO) made a reference to the Transfer Pricing Officer (TPO) regarding international transactions.

What were the issues?

Whether transfer pricing adjustments for interest on supplier's credit are valid when no deduction for such interest was claimed by the assessee and the assessee had no revenue from operations. Also, issues related to set-off of losses and computation of book profits were raised.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B,Section 92CA,Section 92(1),Section 115JB,Section 234A,Section 234B,Section 234C,Section 270A

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Income Tax Appellate Tribunal, Hyderabad ‘B’ Bench, Hyderabad

For Appellant: Ms. M. Narmada, CIT-DR

प्रनत रवीश सूद, जे.एम./PER RAVISH SOOD, J.M.

The present appeal filed by the assessee company is directed against the order passed by the Assessing Officer (“the AO”) u/s 143(3) r.w.s. 144C(13) read with section 144B of the Income-tax Act, 1961 (“the Act”) dated 20.12.2023. The assessee has assailed the impugned order on the following g

The order continues below.

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