https://www.taxtmi.com/caselaws?id=375001 The tribunal partly allowed the appeal of the assessee, directing the AO/TPO to apply a guarantee commission rate of 1% instead of 1.75% for corporate guarantees, following precedent. The tribunal also instructed the AO/TPO to adhere to previous decisions by Co-ordinate Benches regarding the re-characterization of preference shares as interest-free loans, leading to the allowance of specified grounds raised by the assessee. Additionally, disallowances of interest expenses and administrative expenses were deleted based on commercial expediency and Rule 8D(2)(iii) application, respectively. The issue of non-grant of foreign tax credit was remanded for further consideration, while premature penalty proceedings under section 271(1)(c) were dismissed. en-us Wed, 06 Feb 2019 00:00:00 +0530 Wed, 13 Feb 2019 06:09:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=375001 The tribunal partly allowed the appeal of the assessee, directing the AO/TPO to apply a guarantee commission rate of 1% instead of 1.75% for corporate guarantees, following precedent. The tribunal also instructed the AO/TPO to adhere to previous decisions by Co-ordinate Benches regarding the re-characterization of preference shares as interest-free loans, leading to the allowance of specified grounds raised by the assessee. Additionally, disallowances of interest expenses and administrative expenses were deleted based on commercial expediency and Rule 8D(2)(iii) application, respectively. The issue of non-grant of foreign tax credit was remanded for further consideration, while premature penalty proceedings under section 271(1)(c) were dismissed. Case-Laws Income Tax Wed, 06 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=375001