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    <title>2021 (10) TMI 822 - ITAT MUMBAI</title>
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    <description>The Tribunal ruled in favor of the assessee on the issues of guarantee commission adjustment, disallowance under section 14A, and addition due to mismatch in Form 26AS. The Tribunal upheld the ALP of corporate guarantee fees determined by the assessee at 0.43% and directed the AO to delete the adjustment. The Tribunal also directed the AO to delete the additional disallowance under section 14A, citing lack of objective dissatisfaction. Additionally, the Tribunal held that additions based solely on AIR information are unsustainable and ordered the deletion of the addition related to the difference in gross receipts. The Revenue&#039;s appeal challenging the interest rate charged by the assessee on loans to AEs was dismissed due to low tax effect.</description>
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    <pubDate>Tue, 31 Aug 2021 00:00:00 +0530</pubDate>
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      <title>2021 (10) TMI 822 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=413770</link>
      <description>The Tribunal ruled in favor of the assessee on the issues of guarantee commission adjustment, disallowance under section 14A, and addition due to mismatch in Form 26AS. The Tribunal upheld the ALP of corporate guarantee fees determined by the assessee at 0.43% and directed the AO to delete the adjustment. The Tribunal also directed the AO to delete the additional disallowance under section 14A, citing lack of objective dissatisfaction. Additionally, the Tribunal held that additions based solely on AIR information are unsustainable and ordered the deletion of the addition related to the difference in gross receipts. The Revenue&#039;s appeal challenging the interest rate charged by the assessee on loans to AEs was dismissed due to low tax effect.</description>
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      <pubDate>Tue, 31 Aug 2021 00:00:00 +0530</pubDate>
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