https://www.taxtmi.com/caselaws?id=268839 The ITAT Ahmedabad allowed the assessee's appeal by deleting the ALP adjustment related to excess credit period granted to its US AE, holding no comparable real transactions existed and the adjustment lacked commercial reality. It also ruled that corporate guarantees issued as shareholder activities, without impact on profits or assets, do not constitute international transactions under section 92B, thus deleting related ALP adjustments. The tribunal remanded the issue of deductions under sections 80IB and 10B for fresh adjudication per earlier orders. Regarding expenses, it confirmed disallowance of electricity expenses but deleted disallowance of telephone expenses of the MD. However, the tribunal upheld the disallowance of software expenses related to ERP implementation, finding no error in the authorities' decision. en-us Fri, 27 Nov 2015 00:00:00 +0530 Thu, 24 Jul 2025 18:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=268839 The ITAT Ahmedabad allowed the assessee's appeal by deleting the ALP adjustment related to excess credit period granted to its US AE, holding no comparable real transactions existed and the adjustment lacked commercial reality. It also ruled that corporate guarantees issued as shareholder activities, without impact on profits or assets, do not constitute international transactions under section 92B, thus deleting related ALP adjustments. The tribunal remanded the issue of deductions under sections 80IB and 10B for fresh adjudication per earlier orders. Regarding expenses, it confirmed disallowance of electricity expenses but deleted disallowance of telephone expenses of the MD. However, the tribunal upheld the disallowance of software expenses related to ERP implementation, finding no error in the authorities' decision. Case-Laws Income Tax Fri, 27 Nov 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=268839