https://www.taxtmi.com/caselaws?id=336906 The Court upheld the decision of the Income Tax Appellate Tribunal (ITAT) regarding the applicability of transfer pricing exercise on loans advanced to subsidiary/AE. The Court dismissed the revenue's appeal, emphasizing the need for scrutiny by the Transfer Pricing Officer to determine arm's length terms for each case. Additionally, the Court found the deletion of disallowance under Section 14A justified, as the ITAT's decision was fact-dependent and the application of Rule 8D was deemed incorrect. The appeals and pending applications were dismissed based on the factual nature of the findings without raising any legal questions. en-us Mon, 17 Oct 2016 00:00:00 +0530 Fri, 30 Dec 2016 18:14:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=336906 The Court upheld the decision of the Income Tax Appellate Tribunal (ITAT) regarding the applicability of transfer pricing exercise on loans advanced to subsidiary/AE. The Court dismissed the revenue's appeal, emphasizing the need for scrutiny by the Transfer Pricing Officer to determine arm's length terms for each case. Additionally, the Court found the deletion of disallowance under Section 14A justified, as the ITAT's decision was fact-dependent and the application of Rule 8D was deemed incorrect. The appeals and pending applications were dismissed based on the factual nature of the findings without raising any legal questions. Case-Laws Income Tax Mon, 17 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=336906