https://www.taxtmi.com/caselaws?id=275613 ITAT upheld the transfer-pricing approach applying the TNM method for intercompany sales and sustained deletion of CUP-based adjustments. Interest charged at LIBOR+1% on dollar loans was accepted and related adjustment deleted. The tribunal affirmed the appellate finding on guarantee payments and allowed CSR expenditures while confirming an adhoc allowance of Rs.10 lakh for other undocumented business expenses. Bad-debt provision disallowance was upheld. Prior-period items must be netted and only the differential taxed. Losses on foreign-subsidiary loans were remitted to the AO for fresh adjudication. Section 14A disallowance was confirmed on an adhoc basis (Rs.3 lakh) for 2007-08 but excluded from MAT book-profit computation. Deemed-dividend u/s 2(22)(e) was negated and s.10B claim directed to be allowed. en-us Wed, 20 Jun 2018 00:00:00 +0530 Sat, 25 Oct 2025 13:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=275613 ITAT upheld the transfer-pricing approach applying the TNM method for intercompany sales and sustained deletion of CUP-based adjustments. Interest charged at LIBOR+1% on dollar loans was accepted and related adjustment deleted. The tribunal affirmed the appellate finding on guarantee payments and allowed CSR expenditures while confirming an adhoc allowance of Rs.10 lakh for other undocumented business expenses. Bad-debt provision disallowance was upheld. Prior-period items must be netted and only the differential taxed. Losses on foreign-subsidiary loans were remitted to the AO for fresh adjudication. Section 14A disallowance was confirmed on an adhoc basis (Rs.3 lakh) for 2007-08 but excluded from MAT book-profit computation. Deemed-dividend u/s 2(22)(e) was negated and s.10B claim directed to be allowed. Case-Laws Income Tax Wed, 20 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=275613