https://www.taxtmi.com/caselaws?id=444957 ITAT Mumbai allowed the assessee's appeal on multiple grounds. The tribunal held that corporate guarantee commission at 0.35% per annum was at arm's length, requiring no transfer pricing adjustment, following coordinate bench decisions. Regarding disallowance under Section 14A read with Rule 8D, the tribunal found the AO's dissatisfaction was recorded mechanically without proper regard to the assessee's accounts and suo moto disallowance computation, thus deleting the addition. The tribunal also deleted adjustments in book profit computation under Section 115JB as the AO made no discussion or addition in the assessment order. TDS credit claim was allowed following a previous ITAT decision favoring the assessee. en-us Tue, 20 Jun 2023 00:00:00 +0530 Thu, 26 Oct 2023 10:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444957 ITAT Mumbai allowed the assessee's appeal on multiple grounds. The tribunal held that corporate guarantee commission at 0.35% per annum was at arm's length, requiring no transfer pricing adjustment, following coordinate bench decisions. Regarding disallowance under Section 14A read with Rule 8D, the tribunal found the AO's dissatisfaction was recorded mechanically without proper regard to the assessee's accounts and suo moto disallowance computation, thus deleting the addition. The tribunal also deleted adjustments in book profit computation under Section 115JB as the AO made no discussion or addition in the assessment order. TDS credit claim was allowed following a previous ITAT decision favoring the assessee. Case-Laws Income Tax Tue, 20 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444957