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    <title>2016 (11) TMI 245 - ITAT HYDERABAD</title>
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    <description>The Tribunal partially allowed the appeal, remitting several issues back to the AO for reconsideration. The Tribunal directed the TPO to calculate the ALP using the LIBOR rate for international transactions. It instructed the AO to recalculate the disallowance under Section 14A only for investments generating exempt income. The disallowance of commission payment was upheld due to lack of proof of genuineness. Share issue expenses were allowed under Section 35D for a private placement. The apportionment of expenses to the shipping division was remitted for further determination. The disallowance of ESOP expenses was sent back for reconsideration based on proper documentation.</description>
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      <title>2016 (11) TMI 245 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=334227</link>
      <description>The Tribunal partially allowed the appeal, remitting several issues back to the AO for reconsideration. The Tribunal directed the TPO to calculate the ALP using the LIBOR rate for international transactions. It instructed the AO to recalculate the disallowance under Section 14A only for investments generating exempt income. The disallowance of commission payment was upheld due to lack of proof of genuineness. Share issue expenses were allowed under Section 35D for a private placement. The apportionment of expenses to the shipping division was remitted for further determination. The disallowance of ESOP expenses was sent back for reconsideration based on proper documentation.</description>
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