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    <title>2021 (4) TMI 682 - ITAT AHMEDABAD</title>
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    <description>The Tribunal ruled in favor of the assessee on various issues: interest-free loans to associated enterprises were not subject to adjustment under transfer pricing provisions due to commercial expediency; disallowance under Section 14A was not warranted in absence of exempt income; deduction under Section 80IB was allowed for scientific research activities; corporate guarantees were considered international transactions with a 5% markup; no TDS was required on consultancy fees under DTAA; deemed dividend was not applicable as the assessee was not a shareholder; and miscellaneous income and notice pay were eligible for deduction under Section 80IB. The appeals of the assessee were partly allowed, and those of the Revenue were dismissed.</description>
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      <title>2021 (4) TMI 682 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=406566</link>
      <description>The Tribunal ruled in favor of the assessee on various issues: interest-free loans to associated enterprises were not subject to adjustment under transfer pricing provisions due to commercial expediency; disallowance under Section 14A was not warranted in absence of exempt income; deduction under Section 80IB was allowed for scientific research activities; corporate guarantees were considered international transactions with a 5% markup; no TDS was required on consultancy fees under DTAA; deemed dividend was not applicable as the assessee was not a shareholder; and miscellaneous income and notice pay were eligible for deduction under Section 80IB. The appeals of the assessee were partly allowed, and those of the Revenue were dismissed.</description>
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      <pubDate>Mon, 12 Apr 2021 00:00:00 +0530</pubDate>
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