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    <title>2023 (11) TMI 387 - ITAT CHENNAI</title>
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    <description>The ITAT Chennai allowed the assessee&#039;s appeal and dismissed the Revenue&#039;s appeal. For disallowance under section 14A, the tribunal restricted interest disallowance to Rs. 51,29,547 for AY 2012-13 and directed no disallowance for AY 2013-14, finding sufficient interest-free funds exceeded investments generating exempt income. The tribunal allowed interest claims on advances to subsidiaries, recognizing them as business-related expenditure due to common management and business expansion. Transfer pricing adjustment on barite-lumps was deleted as the comparable uncontrolled price method was inappropriate for single transaction comparison, and margin difference fell within permissible 5% variation. Disallowance under section 40(a)(ia) for compensatory charges was deleted as payments to APMDC were compensatory in nature, not interest requiring TDS deduction.</description>
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      <description>The ITAT Chennai allowed the assessee&#039;s appeal and dismissed the Revenue&#039;s appeal. For disallowance under section 14A, the tribunal restricted interest disallowance to Rs. 51,29,547 for AY 2012-13 and directed no disallowance for AY 2013-14, finding sufficient interest-free funds exceeded investments generating exempt income. The tribunal allowed interest claims on advances to subsidiaries, recognizing them as business-related expenditure due to common management and business expansion. Transfer pricing adjustment on barite-lumps was deleted as the comparable uncontrolled price method was inappropriate for single transaction comparison, and margin difference fell within permissible 5% variation. Disallowance under section 40(a)(ia) for compensatory charges was deleted as payments to APMDC were compensatory in nature, not interest requiring TDS deduction.</description>
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