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    <title>2020 (9) TMI 276 - ITAT MUMBAI</title>
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    <description>The appeal was partly allowed, with specific directions given to the Transfer Pricing Officer (TPO) and Assessing Officer (AO) for fresh consideration and adjustments in accordance with the Tribunal&#039;s findings and previous decisions. The Tribunal emphasized the importance of proper benchmarking and verification of facts before making any adjustments. Notably, adjustments regarding Corporate Guarantee to Associated Enterprise were restricted to 0.5% of the guarantee amount until a certain date, and various disallowances were deleted based on commercial expediency and absence of exempt income. Penalties and interest levies were rendered infructuous due to rectification orders.</description>
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      <description>The appeal was partly allowed, with specific directions given to the Transfer Pricing Officer (TPO) and Assessing Officer (AO) for fresh consideration and adjustments in accordance with the Tribunal&#039;s findings and previous decisions. The Tribunal emphasized the importance of proper benchmarking and verification of facts before making any adjustments. Notably, adjustments regarding Corporate Guarantee to Associated Enterprise were restricted to 0.5% of the guarantee amount until a certain date, and various disallowances were deleted based on commercial expediency and absence of exempt income. Penalties and interest levies were rendered infructuous due to rectification orders.</description>
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