ITAT deletes Rs. 19.6 Lakh Addition for AY 2018-19, applying Retrospective 10% Safe Harbour Limit based on Curative Amendment

The ITAT deleted an addition of ₹19.6 lakh for the assessment year 2018-19 by applying a retrospective 10% safe harbor limit, citing a curative amendment. The tribunal held that the amendment aimed to provide relief to taxpayers and should be applied retrospectively to ensure fairness. This decision offers significant relief to taxpayers impacted by earlier high thresholds for transfer pricing adjustments. Legal experts regard this ruling as a key precedent in retrospective application of curative amendments, emphasizing fairness over procedural rigidity. The judgment advises taxpayers to review their past assessments for potential relief under similar amendments. It reflects the judiciary’s role in balancing enforcement with equitable treatment of taxpayers, aligning with the broader objective of promoting voluntary compliance under the tax framework.