https://www.taxtmi.com/caselaws?id=197787 ITAT Mumbai upheld a transfer pricing adjustment limiting the corporate guarantee fee to 0.50% of the gross guarantee value, aligning with Bombay HC precedent. The disallowance of interest under section 36(1)(iii) was reversed, as the tribunal found the expenditure commercially expedient and connected to business purposes, emphasizing a prudent businessman's perspective rather than revenue's viewpoint. The tribunal also directed the grant of full TDS credit and refund after verifying physical TDS certificates, following established HC rulings. Both grounds of the assessee's appeal were allowed for statistical purposes. en-us Wed, 04 Jan 2017 00:00:00 +0530 Wed, 30 Jul 2025 16:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=197787 ITAT Mumbai upheld a transfer pricing adjustment limiting the corporate guarantee fee to 0.50% of the gross guarantee value, aligning with Bombay HC precedent. The disallowance of interest under section 36(1)(iii) was reversed, as the tribunal found the expenditure commercially expedient and connected to business purposes, emphasizing a prudent businessman's perspective rather than revenue's viewpoint. The tribunal also directed the grant of full TDS credit and refund after verifying physical TDS certificates, following established HC rulings. Both grounds of the assessee's appeal were allowed for statistical purposes. Case-Laws Income Tax Wed, 04 Jan 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=197787