https://www.taxtmi.com/caselaws?id=310452 ITAT Mumbai allowed the appeal regarding transfer pricing adjustment for corporate guarantee commission. Following coordinate bench decisions for assessment years 2011-12 to 2014-15, the tribunal held that corporate guarantee commission at 0.35% per annum was at arm's length, requiring no transfer pricing adjustment. The AO's addition confirmed by DRP was deleted. Regarding Section 14A disallowance, the tribunal found AO's dissatisfaction recording was mechanical and not in accordance with Section 14A(2) mandate, as it ignored appellant's methodical computation of actual expenditure. The disallowance under Section 14A read with Rule 8D was deleted, and appellant's grounds were allowed. en-us Wed, 07 Dec 2022 00:00:00 +0530 Thu, 26 Oct 2023 07:43:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310452 ITAT Mumbai allowed the appeal regarding transfer pricing adjustment for corporate guarantee commission. Following coordinate bench decisions for assessment years 2011-12 to 2014-15, the tribunal held that corporate guarantee commission at 0.35% per annum was at arm's length, requiring no transfer pricing adjustment. The AO's addition confirmed by DRP was deleted. Regarding Section 14A disallowance, the tribunal found AO's dissatisfaction recording was mechanical and not in accordance with Section 14A(2) mandate, as it ignored appellant's methodical computation of actual expenditure. The disallowance under Section 14A read with Rule 8D was deleted, and appellant's grounds were allowed. Case-Laws Income Tax Wed, 07 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310452