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ITAT dismissed revenue's appeal on multiple grounds. Regarding 'on-money' addition, ITAT upheld CIT(A)'s restriction to 25% of AO's addition, finding AO lacked evidentiary basis for extrapolation from 99acres.com reference prices. On transfer pricing adjustments for debenture interest and expenses, ITAT affirmed CIT(A)'s deletion, noting TPO failed to apply prescribed methods under section 92C(1) read with Rule 10AB for determining arm's length price. Court held CCD issuance was quasi-capital nature and cited Shell India Markets precedent that share issuance to non-resident associated enterprises doesn't attract transfer pricing provisions. For various business expenses disallowance, ITAT confirmed CIT(A)'s allowance, finding expenses were incurred wholly and exclusively for business purposes without capital or personal nature.
ITAT dismissed revenue's appeal on multiple grounds. Regarding 'on-money' addition, ITAT upheld CIT(A)'s restriction to 25% of AO's addition, finding AO lacked evidentiary basis for extrapolation from 99acres.com reference prices. On transfer pricing adjustments for debenture interest and expenses, ITAT affirmed CIT(A)'s deletion, noting TPO failed to apply prescribed methods under section 92C(1) read with Rule 10AB for determining arm's length price. Court held CCD issuance was quasi-capital nature and cited Shell India Markets precedent that share issuance to non-resident associated enterprises doesn't attract transfer pricing provisions. For various business expenses disallowance, ITAT confirmed CIT(A)'s allowance, finding expenses were incurred wholly and exclusively for business purposes without capital or personal nature.
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