https://www.taxtmi.com/caselaws?id=446254 The ITAT Mumbai upheld CIT(A)'s decision reducing corporate guarantee fee rate from 2.5% to 0.5% for international transactions with associated enterprises, following precedent from earlier assessment years. The Tribunal confirmed LIBOR plus 1% as arm's length interest rate for loans to AEs and rejected the assessee's claim for proportionate premium deduction on optionally convertible debentures, ruling that subsequent commercial arrangements cannot be applied retroactively. The Tribunal allowed deductions for interest expenses on subsidiary share acquisition and ESOP expenses under Section 37(1), and permitted mark-to-market losses on forward contracts as legitimate business expenses. However, delayed ESIC contributions were disallowed following Supreme Court precedent in Checkmate Services case. en-us Wed, 18 Oct 2023 00:00:00 +0530 Tue, 28 Nov 2023 15:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446254 The ITAT Mumbai upheld CIT(A)'s decision reducing corporate guarantee fee rate from 2.5% to 0.5% for international transactions with associated enterprises, following precedent from earlier assessment years. The Tribunal confirmed LIBOR plus 1% as arm's length interest rate for loans to AEs and rejected the assessee's claim for proportionate premium deduction on optionally convertible debentures, ruling that subsequent commercial arrangements cannot be applied retroactively. The Tribunal allowed deductions for interest expenses on subsidiary share acquisition and ESOP expenses under Section 37(1), and permitted mark-to-market losses on forward contracts as legitimate business expenses. However, delayed ESIC contributions were disallowed following Supreme Court precedent in Checkmate Services case. Case-Laws Income Tax Wed, 18 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446254