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
Khush Trivedi
Jun 1, 2026
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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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Khush Trivedi
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AHMEDABAD, Gujarat, India
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