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    <title>2021 (12) TMI 1248 - ITAT DELHI</title>
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    <description>The Appellate Tribunal ruled in favor of the Assessee regarding the disallowance of interest expenses under Section 36(1)(iii) of the Income Tax Act for the assessment year 2015-16. The addition made by the Assessing Officer was deleted by the Commissioner, emphasizing the prudent businessman&#039;s perspective and the nexus between investments and business objectives. However, the Tribunal partially upheld the Transfer Pricing Adjustment related to corporate guarantees to overseas associated enterprises, reducing the interest rate to 0.5%. The consistent legal stance on corporate guarantees as international transactions led to the dismissal of both cross appeals by the Revenue Department and the Assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=416482</link>
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