https://www.taxtmi.com/caselaws?id=437346 The Tribunal partly allowed the appeals, granting relief to the assessee on various grounds. The Tribunal determined that a corporate guarantee constitutes an international transaction, set the Arm's Length Price for the guarantee commission at 0.35%, and ruled that no disallowance under Section 14A was warranted. It also held that foreign exchange loss should be treated as revenue expenditure, deleted the addition under Section 43CA, and removed the disallowance under Section 40(a)(i). The Tribunal deemed the initiation of penalty proceedings premature and directed the AO to grant MAT and TDS credits appropriately. en-us Mon, 17 Apr 2023 00:00:00 +0530 Thu, 04 May 2023 12:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437346 The Tribunal partly allowed the appeals, granting relief to the assessee on various grounds. The Tribunal determined that a corporate guarantee constitutes an international transaction, set the Arm's Length Price for the guarantee commission at 0.35%, and ruled that no disallowance under Section 14A was warranted. It also held that foreign exchange loss should be treated as revenue expenditure, deleted the addition under Section 43CA, and removed the disallowance under Section 40(a)(i). The Tribunal deemed the initiation of penalty proceedings premature and directed the AO to grant MAT and TDS credits appropriately. Case-Laws Income Tax Mon, 17 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437346