https://www.taxtmi.com/caselaws?id=444912 ITAT Ahmedabad decided multiple transfer pricing and tax issues. The assessee failed to demonstrate that advances to subsidiaries were quasi-capital rather than loans, upholding TP adjustment on notional interest. Strategic investment exclusion from Rule 8D disallowance was rejected following prior year precedent. However, the tribunal favored the assessee on liaison support services benchmarking, rejecting TPO's downward adjustment from 3% to 2%, finding assessee's comparables appropriate while TPO's were functionally different. Carbon credit sale proceeds were held as capital receipts following established precedent. en-us Wed, 11 Oct 2023 00:00:00 +0530 Wed, 25 Oct 2023 11:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444912 ITAT Ahmedabad decided multiple transfer pricing and tax issues. The assessee failed to demonstrate that advances to subsidiaries were quasi-capital rather than loans, upholding TP adjustment on notional interest. Strategic investment exclusion from Rule 8D disallowance was rejected following prior year precedent. However, the tribunal favored the assessee on liaison support services benchmarking, rejecting TPO's downward adjustment from 3% to 2%, finding assessee's comparables appropriate while TPO's were functionally different. Carbon credit sale proceeds were held as capital receipts following established precedent. Case-Laws Income Tax Wed, 11 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444912