https://www.taxtmi.com/caselaws?id=411632 The tribunal upheld the treatment of corporate guarantees as international transactions based on the Explanation to Section 92B, citing the decision in Pr.CIT Vs. M/s. Redington (India) Limited. It directed a 0.53% commission rate and limited the adjustment to the utilized amount. Regarding Section 14A read with Rule 8D, disallowance was deleted for an assessee with no exempt income. For another assessee, lack of satisfaction led to remand for fresh adjudication. A third assessee's disallowance was affirmed due to insufficient details. The tribunal's judgment emphasized consistency and adherence to legal precedents, partly allowing the appeals with specific directions for re-computation and fresh adjudication where necessary. en-us Tue, 24 Aug 2021 00:00:00 +0530 Mon, 30 Aug 2021 16:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=411632 The tribunal upheld the treatment of corporate guarantees as international transactions based on the Explanation to Section 92B, citing the decision in Pr.CIT Vs. M/s. Redington (India) Limited. It directed a 0.53% commission rate and limited the adjustment to the utilized amount. Regarding Section 14A read with Rule 8D, disallowance was deleted for an assessee with no exempt income. For another assessee, lack of satisfaction led to remand for fresh adjudication. A third assessee's disallowance was affirmed due to insufficient details. The tribunal's judgment emphasized consistency and adherence to legal precedents, partly allowing the appeals with specific directions for re-computation and fresh adjudication where necessary. Case-Laws Income Tax Tue, 24 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=411632