https://www.taxtmi.com/caselaws?id=435910 ITAT upheld the assessee's transfer-pricing study, accepting interest rates of 9% and 12% on CCDs and recharacterisation as ECBs, and held the royalty payment at arm's length. The tribunal deleted the disallowance under section 14A r.w. Rule 8D and directed that no addition under section 14A be made when computing book profits under section 115JB. The AO was directed to verify and consider the claim for short credit of TDS and to adjudicate consequential interest under section 244A in accordance with law. en-us Mon, 14 Nov 2022 00:00:00 +0530 Wed, 27 Aug 2025 14:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435910 ITAT upheld the assessee's transfer-pricing study, accepting interest rates of 9% and 12% on CCDs and recharacterisation as ECBs, and held the royalty payment at arm's length. The tribunal deleted the disallowance under section 14A r.w. Rule 8D and directed that no addition under section 14A be made when computing book profits under section 115JB. The AO was directed to verify and consider the claim for short credit of TDS and to adjudicate consequential interest under section 244A in accordance with law. Case-Laws Income Tax Mon, 14 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435910