https://www.taxtmi.com/caselaws?id=446589 ITAT Mumbai dismissed Revenue's appeal regarding transfer pricing adjustments for corporate guarantee and other disallowances. The court held that no TP adjustment was warranted for performance guarantee given by assessee to secure Dubai bridge construction contract through subsidiary, as assessee bore entire risk, deployed assets, and reaped 99% profits while associated enterprise performed negligible functions. Interest disallowance under section 36(1)(iii) was upheld following earlier tribunal decisions limiting disallowance to incremental loans from specific date. Depreciation claim on speedboat was allowed based on precedent where assessee had possession and business use despite principal's ownership. Professional fees for arbitration award were allowed as legitimate business expenditure, rejecting Revenue's argument linking it to excluded arbitration income. en-us Thu, 09 Nov 2023 00:00:00 +0530 Wed, 06 Dec 2023 10:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446589 ITAT Mumbai dismissed Revenue's appeal regarding transfer pricing adjustments for corporate guarantee and other disallowances. The court held that no TP adjustment was warranted for performance guarantee given by assessee to secure Dubai bridge construction contract through subsidiary, as assessee bore entire risk, deployed assets, and reaped 99% profits while associated enterprise performed negligible functions. Interest disallowance under section 36(1)(iii) was upheld following earlier tribunal decisions limiting disallowance to incremental loans from specific date. Depreciation claim on speedboat was allowed based on precedent where assessee had possession and business use despite principal's ownership. Professional fees for arbitration award were allowed as legitimate business expenditure, rejecting Revenue's argument linking it to excluded arbitration income. Case-Laws Income Tax Thu, 09 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446589