https://www.taxtmi.com/caselaws?id=407415 The Tribunal upheld the deletion of additions made by the Revenue under sections 69 and on account of interest on External Commercial Borrowings (ECB) and guarantee fee and service fee paid to the holding company. The Tribunal found that the Revenue's additions were based on surmises and lacked substantive evidence, emphasizing the limited jurisdiction of the Transfer Pricing Officer (TPO) in determining Arm's Length Price (ALP) and not questioning commercial expediency. The Tribunal dismissed the Revenue's appeals for both assessment years, citing the lack of merit in the grounds raised. en-us Fri, 26 Mar 2021 00:00:00 +0530 Tue, 11 May 2021 13:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=407415 The Tribunal upheld the deletion of additions made by the Revenue under sections 69 and on account of interest on External Commercial Borrowings (ECB) and guarantee fee and service fee paid to the holding company. The Tribunal found that the Revenue's additions were based on surmises and lacked substantive evidence, emphasizing the limited jurisdiction of the Transfer Pricing Officer (TPO) in determining Arm's Length Price (ALP) and not questioning commercial expediency. The Tribunal dismissed the Revenue's appeals for both assessment years, citing the lack of merit in the grounds raised. Case-Laws Income Tax Fri, 26 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=407415