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    <title>2019 (9) TMI 1328 - ITAT MUMBAI</title>
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    <description>The appeal was partly allowed, with issues related to deduction under Section 80IC and expenditure on buyback of shares being decided in favor of the assessee for statistical purposes, to be reconsidered by the Assessing Officer. However, the determination of Arm&#039;s Length Price (ALP) for corporate guarantees and interest rates for loans to Associated Enterprises were resolved in favor of the revenue, setting the ALP at 0.5% for corporate guarantees and requiring consideration of the interest rate in the country of loan consumption. The ITAT directed fresh adjudication on various issues based on relevant judicial precedents and factual assessments.</description>
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      <link>https://www.taxtmi.com/caselaws?id=286516</link>
      <description>The appeal was partly allowed, with issues related to deduction under Section 80IC and expenditure on buyback of shares being decided in favor of the assessee for statistical purposes, to be reconsidered by the Assessing Officer. However, the determination of Arm&#039;s Length Price (ALP) for corporate guarantees and interest rates for loans to Associated Enterprises were resolved in favor of the revenue, setting the ALP at 0.5% for corporate guarantees and requiring consideration of the interest rate in the country of loan consumption. The ITAT directed fresh adjudication on various issues based on relevant judicial precedents and factual assessments.</description>
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