ITAT Grants Cummins India Relief On TP Adjustment And Deductions

The ITAT granted relief to Cummins India by deleting a transfer pricing adjustment and allowing deductions under Sections 10AA and 80JJAA despite a one-day delay in return filing. The Tribunal emphasized substantive compliance over procedural lapses and rejected hyper-technical denial of benefits. The ruling strengthens taxpayer protections in TP disputes and deduction claims where intent and eligibility are clearly established.