https://www.taxtmi.com/caselaws?id=447186 ITAT Ahmedabad ruled on multiple issues in this tax appeal. The court dismissed the assessee's depreciation claim on land development expenditure, holding that since the assessee failed to challenge the initial disallowance in AY 2011-12, the matter reached finality and cannot be re-agitated. However, depreciation on right to use leasehold land was allowed as it qualified as intangible asset. Regarding section 14A disallowances, administrative expenses were restricted to Rs. 20 lacs under rule 8D, with Rs. 25 lacs added to book profit under section 115JB. The tribunal confirmed corporate guarantee as international transaction requiring benchmarking but found no adjustment warranted. For interest-free loans to foreign subsidiary, the court held LIBOR + 2.8% as arm's length price, deleting the upward adjustment. en-us Thu, 30 Nov 2023 00:00:00 +0530 Tue, 19 Dec 2023 10:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447186 ITAT Ahmedabad ruled on multiple issues in this tax appeal. The court dismissed the assessee's depreciation claim on land development expenditure, holding that since the assessee failed to challenge the initial disallowance in AY 2011-12, the matter reached finality and cannot be re-agitated. However, depreciation on right to use leasehold land was allowed as it qualified as intangible asset. Regarding section 14A disallowances, administrative expenses were restricted to Rs. 20 lacs under rule 8D, with Rs. 25 lacs added to book profit under section 115JB. The tribunal confirmed corporate guarantee as international transaction requiring benchmarking but found no adjustment warranted. For interest-free loans to foreign subsidiary, the court held LIBOR + 2.8% as arm's length price, deleting the upward adjustment. Case-Laws Income Tax Thu, 30 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447186