Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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ITAT partly allowed the assessee's appeal. Disallowance of interest on housing loan under s.24(b) and deduction under s.80C towards principal repayment were upheld as no housing loan certificate or sanction letter was produced. Disallowances on sales promotion, travelling expenses, accounting and consultancy charges, bonus and ex gratia, and addition relating to unexplained capital introduction treated as income from other sources were also confirmed for failure to substantiate genuineness and business nexus. Disallowance of consultancy charges and addition under s.68 towards unsecured loans were set aside to the AO for de novo adjudication. On GST disallowance under s.43B, AO was directed to verify actual payment before return filing; this ground was allowed for statistical purposes.
ITAT partly allowed the assessee's appeal. Disallowance of interest on housing loan under s.24(b) and deduction under s.80C towards principal repayment were upheld as no housing loan certificate or sanction letter was produced. Disallowances on sales promotion, travelling expenses, accounting and consultancy charges, bonus and ex gratia, and addition relating to unexplained capital introduction treated as income from other sources were also confirmed for failure to substantiate genuineness and business nexus. Disallowance of consultancy charges and addition under s.68 towards unsecured loans were set aside to the AO for de novo adjudication. On GST disallowance under s.43B, AO was directed to verify actual payment before return filing; this ground was allowed for statistical purposes.
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