https://www.taxtmi.com/caselaws?id=385037 ITAT partly allowed the appeal. On transfer pricing, it upheld in principle that the ALP for interest on loans to the German AE must be based on rates in Germany, not India, and directed recomputation applying EURIBOR + 2%, with the effective rate capped at 4.42% if higher. It affirmed the CIT(A)'s computation of deduction u/s 10A, including exclusion of telecommunication and foreign-branch employee costs from both export and total turnover, and inclusion of DTM/onsite service income as profits of the undertaking. Disallowance u/s 14A was sustained without applying Rule 8D. For MAT u/s 115JB, discount on lapsed ESOPs credited to General Reserve was held not adjustable to book profit. The ground relating to s.41(1) was allowed, and that relating to s.115JB rejected. en-us Mon, 05 Aug 2019 00:00:00 +0530 Wed, 03 Jun 2026 15:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=385037 ITAT partly allowed the appeal. On transfer pricing, it upheld in principle that the ALP for interest on loans to the German AE must be based on rates in Germany, not India, and directed recomputation applying EURIBOR + 2%, with the effective rate capped at 4.42% if higher. It affirmed the CIT(A)'s computation of deduction u/s 10A, including exclusion of telecommunication and foreign-branch employee costs from both export and total turnover, and inclusion of DTM/onsite service income as profits of the undertaking. Disallowance u/s 14A was sustained without applying Rule 8D. For MAT u/s 115JB, discount on lapsed ESOPs credited to General Reserve was held not adjustable to book profit. The ground relating to s.41(1) was allowed, and that relating to s.115JB rejected. Case-Laws Income Tax Mon, 05 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=385037