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The ITAT allowed the assessee's plea to remit the issue of royalty payment disallowance back to the TPO for reconsideration, subject to the final outcome of the APA with the CBDT, thus granting Ground No.2 for statistical purposes. The Tribunal upheld the DRP's determination of the ALP on interest payments on ECBs at LIBOR plus 200 basis points, dismissing the assessee's challenge. Regarding leasehold amortization charges, the ITAT ruled that such charges must be amortized proportionately over the lease period and allowed the assessee's claim of leasehold amortization as revenue expenditure for the relevant year.
The ITAT allowed the assessee's plea to remit the issue of royalty payment disallowance back to the TPO for reconsideration, subject to the final outcome of the APA with the CBDT, thus granting Ground No.2 for statistical purposes. The Tribunal upheld the DRP's determination of the ALP on interest payments on ECBs at LIBOR plus 200 basis points, dismissing the assessee's challenge. Regarding leasehold amortization charges, the ITAT ruled that such charges must be amortized proportionately over the lease period and allowed the assessee's claim of leasehold amortization as revenue expenditure for the relevant year.
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