ITAT Deletes Rs 15.77 Crore Disallowance, Holds Business Expediency Cannot Be Reopened Under Section 37(1):

The ITAT Delhi held that once a transaction is covered under a binding APA under Section 92CC, the Revenue cannot disallow the same expenditure under Section 37(1), deleting the Rs 15.77 crore addition.
ITAT Rules Section 37(1) Cannot Override Covered Transactions

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ITAT Deletes Rs 15.77 Crore Disallowance, Holds Business Expediency Cannot Be Reopened Under Section 37(1)
The ITAT Delhi held that once a transaction is covered under a binding APA under Section 92CC, the Revenue cannot disallow the same expenditure under Section 37(1), deleting the Rs 15.77 crore addition.
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