https://www.taxtmi.com/caselaws?id=404084 Transfer pricing provisions apply only where an arrangement creates a real financial obligation or risk; a mere letter of comfort without guarantee-like liability did not support an adjustment. Section 14A disallowance cannot be made by applying Rule 8D unless the Assessing Officer records the required dissatisfaction under section 14A(2), so the adjustment failed. Education cess on income-tax was held deductible on binding precedent, and unclaimed additional depreciation could be carried forward to the next year where only half was claimed because the asset was used for less than 180 days. Corporate guarantee commission at 0.20%, weighted deduction for R&D, television advertisement, and trip-scheme expenditure were upheld on settled facts and precedent, while some treaty-based claims were remitted for fresh examination. en-us Wed, 03 Feb 2021 00:00:00 +0530 Thu, 01 May 2025 17:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=404084 Transfer pricing provisions apply only where an arrangement creates a real financial obligation or risk; a mere letter of comfort without guarantee-like liability did not support an adjustment. Section 14A disallowance cannot be made by applying Rule 8D unless the Assessing Officer records the required dissatisfaction under section 14A(2), so the adjustment failed. Education cess on income-tax was held deductible on binding precedent, and unclaimed additional depreciation could be carried forward to the next year where only half was claimed because the asset was used for less than 180 days. Corporate guarantee commission at 0.20%, weighted deduction for R&D, television advertisement, and trip-scheme expenditure were upheld on settled facts and precedent, while some treaty-based claims were remitted for fresh examination. Case-Laws Income Tax Wed, 03 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=404084