https://www.taxtmi.com/caselaws?id=361446 The Tribunal partially allowed the assessee's appeal and dismissed the Revenue's appeal. The judgment addressed transfer pricing adjustments on guarantee fees, limiting the adjustment percentages for corporate and counter guarantees. It ruled in favor of the assessee regarding disallowance under section 14A, stating no disallowance was necessary due to sufficient own funds. Additionally, it supported the assessee on the disallowance under section 40(a)(ia), finding the payments not qualifying as royalty. The decision aligned with legal provisions and precedents, providing a comprehensive resolution to the issues raised. en-us Mon, 28 May 2018 00:00:00 +0530 Sat, 23 Oct 2021 10:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=361446 The Tribunal partially allowed the assessee's appeal and dismissed the Revenue's appeal. The judgment addressed transfer pricing adjustments on guarantee fees, limiting the adjustment percentages for corporate and counter guarantees. It ruled in favor of the assessee regarding disallowance under section 14A, stating no disallowance was necessary due to sufficient own funds. Additionally, it supported the assessee on the disallowance under section 40(a)(ia), finding the payments not qualifying as royalty. The decision aligned with legal provisions and precedents, providing a comprehensive resolution to the issues raised. Case-Laws Income Tax Mon, 28 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=361446