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The ITAT modified the CIT(A)'s order on transfer-pricing adjustment for a corporate guarantee: rejecting the CIT(A)'s adoption of a 0.2% guarantee fee, the Tribunal directed the AO to sustain an addition at 0.5% of the guarantee value, partially allowing Revenue's ground. Regarding disallowance of aircraft depreciation and maintenance, the ITAT affirmed the CIT(A)'s factual finding that relevant logbooks and movement sheets were produced to the AO and CIT(A); Revenue's challenge was not maintained as it did not properly contest the finding as perverse. Consequently, the CIT(A)'s allowance of those expenses stands and no further disallowance is directed.
The ITAT modified the CIT(A)'s order on transfer-pricing adjustment for a corporate guarantee: rejecting the CIT(A)'s adoption of a 0.2% guarantee fee, the Tribunal directed the AO to sustain an addition at 0.5% of the guarantee value, partially allowing Revenue's ground. Regarding disallowance of aircraft depreciation and maintenance, the ITAT affirmed the CIT(A)'s factual finding that relevant logbooks and movement sheets were produced to the AO and CIT(A); Revenue's challenge was not maintained as it did not properly contest the finding as perverse. Consequently, the CIT(A)'s allowance of those expenses stands and no further disallowance is directed.
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