Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
The ITAT set aside the addition of interest paid on CCDs benchmarked at LIBOR plus 200 bps, holding SBI-PLR as the appropriate rate. It directed deletion of such addition by AO/TPO. The Tribunal also reversed the addition of notional interest on overdue AE receivables benchmarked at SBI short-term deposit rate, mandating computation using LIBOR plus 200 bps after a 30-day credit period. The assessee's weighted average credit period argument was rejected. Depreciation on goodwill arising from amalgamation was disallowed, affirming AO/DRP's view that the goodwill was not genuine. Under section 14A read with Rule 8D, the Tribunal partially allowed the assessee's appeal by reducing disallowance to net of suo motu disallowance already accounted for. Deduction under section 10AA was upheld on enhanced profits post goodwill depreciation disallowance. The claim for section 80G deduction was remanded for fresh verification of donation source. Foreign tax credit claims were directed to be verified and allowed if substantiated. Interest under sections 234B and 234D to be recomputed accordingly.
The ITAT set aside the addition of interest paid on CCDs benchmarked at LIBOR plus 200 bps, holding SBI-PLR as the appropriate rate. It directed deletion of such addition by AO/TPO. The Tribunal also reversed the addition of notional interest on overdue AE receivables benchmarked at SBI short-term deposit rate, mandating computation using LIBOR plus 200 bps after a 30-day credit period. The assessee's weighted average credit period argument was rejected. Depreciation on goodwill arising from amalgamation was disallowed, affirming AO/DRP's view that the goodwill was not genuine. Under section 14A read with Rule 8D, the Tribunal partially allowed the assessee's appeal by reducing disallowance to net of suo motu disallowance already accounted for. Deduction under section 10AA was upheld on enhanced profits post goodwill depreciation disallowance. The claim for section 80G deduction was remanded for fresh verification of donation source. Foreign tax credit claims were directed to be verified and allowed if substantiated. Interest under sections 234B and 234D to be recomputed accordingly.
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