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    <title>2013 (6) TMI 420 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai set aside the disallowance of deduction under section 10A related to reallocation of common head office expenses among units in a Software Technology Park, directing the AO to reconsider the issue after adding back originally allocated expenses and allowing the assessee a hearing. Regarding transfer pricing adjustments on interest receipts from loans to an AE, the tribunal held that the CUP method benchmarking against LIBOR was appropriate, and since the assessee charged interest above LIBOR, no adjustment was warranted. The AO&#039;s order was set aside and the assessee&#039;s grounds allowed. On interest under section 234B, the tribunal held that it is mandatory but consequential, directing the AO to compute it based on upheld additions or adjustments.</description>
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    <pubDate>Wed, 05 Jun 2013 00:00:00 +0530</pubDate>
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      <title>2013 (6) TMI 420 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=234595</link>
      <description>The ITAT Mumbai set aside the disallowance of deduction under section 10A related to reallocation of common head office expenses among units in a Software Technology Park, directing the AO to reconsider the issue after adding back originally allocated expenses and allowing the assessee a hearing. Regarding transfer pricing adjustments on interest receipts from loans to an AE, the tribunal held that the CUP method benchmarking against LIBOR was appropriate, and since the assessee charged interest above LIBOR, no adjustment was warranted. The AO&#039;s order was set aside and the assessee&#039;s grounds allowed. On interest under section 234B, the tribunal held that it is mandatory but consequential, directing the AO to compute it based on upheld additions or adjustments.</description>
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      <pubDate>Wed, 05 Jun 2013 00:00:00 +0530</pubDate>
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