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    <title>2023 (10) TMI 1313 - ITAT MUMBAI</title>
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    <description>The ITAT MUMBAI-AT delivered a mixed decision across multiple tax issues. The tribunal ruled in favor of the assessee on several matters including disallowance u/s 14A where AO failed to examine assessee&#039;s workings before applying Rule 8D, deletion of interest on tax refund from MAT computation, and various transfer pricing adjustments regarding comparable company selections and guarantee commission calculations using yield spread approach. The tribunal also upheld CIT(A)&#039;s decisions on depreciation claims and section 10AA deductions. However, the tribunal decided against the assessee on scientific research expense deduction u/s 35(2AB) due to lack of DSIR approval and depreciation disallowance related to non-genuine steel purchases from earlier years. Several issues were restored to AO for fresh examination including foreign tax credit claims, land acquisition capital gains, and section 50C additions where material evidence wasn&#039;t properly confronted with the assessee.</description>
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    <pubDate>Wed, 18 Oct 2023 00:00:00 +0530</pubDate>
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      <description>The ITAT MUMBAI-AT delivered a mixed decision across multiple tax issues. The tribunal ruled in favor of the assessee on several matters including disallowance u/s 14A where AO failed to examine assessee&#039;s workings before applying Rule 8D, deletion of interest on tax refund from MAT computation, and various transfer pricing adjustments regarding comparable company selections and guarantee commission calculations using yield spread approach. The tribunal also upheld CIT(A)&#039;s decisions on depreciation claims and section 10AA deductions. However, the tribunal decided against the assessee on scientific research expense deduction u/s 35(2AB) due to lack of DSIR approval and depreciation disallowance related to non-genuine steel purchases from earlier years. Several issues were restored to AO for fresh examination including foreign tax credit claims, land acquisition capital gains, and section 50C additions where material evidence wasn&#039;t properly confronted with the assessee.</description>
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