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ITAT Decision Summary: The ITAT comprehensively allowed multiple tax-related claims for the assessee, including: (a) validating internal CUP benchmarking for interest on advances to associated enterprises, (b) rejecting notional interest adjustments on outstanding receivables, (c) permitting weighted deduction under section 35(2AB) for R&D expenditure, (d) upholding depreciation on goodwill from intra-group amalgamation, (e) deleting disallowances related to common expense allocation, (f) rejecting interest capitalization disallowance under section 36(1)(iii), (g) dismissing section 14A disallowance, and (h) upholding non-deduction of TDS on non-resident commission. The tribunal consistently followed precedential rulings and applied principles of commercial reality, predominantly deciding in favor of the assessee across multiple tax dispute grounds.
ITAT Decision Summary: The ITAT comprehensively allowed multiple tax-related claims for the assessee, including: (a) validating internal CUP benchmarking for interest on advances to associated enterprises, (b) rejecting notional interest adjustments on outstanding receivables, (c) permitting weighted deduction under section 35(2AB) for R&D expenditure, (d) upholding depreciation on goodwill from intra-group amalgamation, (e) deleting disallowances related to common expense allocation, (f) rejecting interest capitalization disallowance under section 36(1)(iii), (g) dismissing section 14A disallowance, and (h) upholding non-deduction of TDS on non-resident commission. The tribunal consistently followed precedential rulings and applied principles of commercial reality, predominantly deciding in favor of the assessee across multiple tax dispute grounds.
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