https://www.taxtmi.com/caselaws?id=269655 The Tribunal partly allowed the appeal, upholding the Transfer Pricing (TP) Adjustment and disallowance under Section 14A, while allowing the deduction under Section 10A. The issue concerning Short Term Capital Gains (STCG) was dismissed as academic. The Tribunal found that the taxpayer failed to substantiate the TP adjustment and did not maintain necessary documentation, leading to the ALP being treated as zero. Additionally, the Tribunal ruled that the disallowance under Section 14A should not be based on net interest, and the deduction under Section 10A was justified as there was no reconstitution of business. en-us Fri, 26 Sep 2014 00:00:00 +0530 Fri, 18 Dec 2015 12:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=269655 The Tribunal partly allowed the appeal, upholding the Transfer Pricing (TP) Adjustment and disallowance under Section 14A, while allowing the deduction under Section 10A. The issue concerning Short Term Capital Gains (STCG) was dismissed as academic. The Tribunal found that the taxpayer failed to substantiate the TP adjustment and did not maintain necessary documentation, leading to the ALP being treated as zero. Additionally, the Tribunal ruled that the disallowance under Section 14A should not be based on net interest, and the deduction under Section 10A was justified as there was no reconstitution of business. Case-Laws Income Tax Fri, 26 Sep 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=269655