https://www.taxtmi.com/caselaws?id=439489 ITAT MUMBAI upheld deletion of a transfer-pricing adjustment for inter-group central services, finding contemporaneous evidence of service rendition and commensurate benefit and following a coordinate-bench benchmarking analysis. The tribunal deleted the disallowance under s.14A read with Rule 8D, noting the AO applied Rule 8D without recording requisite satisfaction or examining whether investments yielded exempt income. The tribunal also deleted the addition for ESOP expenses, holding they had not crystallised and were capital in nature. en-us Thu, 11 May 2023 00:00:00 +0530 Sat, 25 Oct 2025 13:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439489 ITAT MUMBAI upheld deletion of a transfer-pricing adjustment for inter-group central services, finding contemporaneous evidence of service rendition and commensurate benefit and following a coordinate-bench benchmarking analysis. The tribunal deleted the disallowance under s.14A read with Rule 8D, noting the AO applied Rule 8D without recording requisite satisfaction or examining whether investments yielded exempt income. The tribunal also deleted the addition for ESOP expenses, holding they had not crystallised and were capital in nature. Case-Laws Income Tax Thu, 11 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439489