https://www.taxtmi.com/caselaws?id=447243 ITAT Mumbai ruled in favor of the assessee on multiple grounds. For A.Y. 2007-08, disallowance under Section 14A was restricted to 5% of exempt income since Rule 8D was not applicable before A.Y. 2008-09. The CIT(A)'s enhancement applying Rule 8D was set aside. Settlement claims expenditure disallowance was deleted following the Tribunal's earlier decision for A.Y. 2005-06. Regarding transfer pricing, the Tribunal upheld that issuance of Letter of Comfort to associated enterprise does not constitute an international transaction, distinguishing it from corporate guarantee, and dismissed Revenue's appeal following consistent precedent. en-us Thu, 30 Nov 2023 00:00:00 +0530 Wed, 20 Dec 2023 11:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447243 ITAT Mumbai ruled in favor of the assessee on multiple grounds. For A.Y. 2007-08, disallowance under Section 14A was restricted to 5% of exempt income since Rule 8D was not applicable before A.Y. 2008-09. The CIT(A)'s enhancement applying Rule 8D was set aside. Settlement claims expenditure disallowance was deleted following the Tribunal's earlier decision for A.Y. 2005-06. Regarding transfer pricing, the Tribunal upheld that issuance of Letter of Comfort to associated enterprise does not constitute an international transaction, distinguishing it from corporate guarantee, and dismissed Revenue's appeal following consistent precedent. Case-Laws Income Tax Thu, 30 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447243