https://www.taxtmi.com/caselaws?id=447752 ITAT Kolkata upheld CIT(A)'s decision on corporate guarantee fees, finding assessee's 0.30% rate exceeded the tribunal's previously established 0.25% arm's length price. For royalty income, ITAT confirmed WACC method applicability for brand valuation as risky intangible, rejecting revenue's challenge. Section 14A disallowance was restricted to investments yielding dividend income only. VAT subsidy was held capital receipt under industrial policy objectives. However, ITAT ruled depreciable assets sold after three years remain short-term capital gains under Section 50, taxable at normal rates. Dividend distribution tax under Section 115O applies regardless of recipient residency. Lease premium deduction was allowed following Balmer Lawrie precedent. en-us Fri, 27 Oct 2023 00:00:00 +0530 Wed, 03 Jan 2024 11:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447752 ITAT Kolkata upheld CIT(A)'s decision on corporate guarantee fees, finding assessee's 0.30% rate exceeded the tribunal's previously established 0.25% arm's length price. For royalty income, ITAT confirmed WACC method applicability for brand valuation as risky intangible, rejecting revenue's challenge. Section 14A disallowance was restricted to investments yielding dividend income only. VAT subsidy was held capital receipt under industrial policy objectives. However, ITAT ruled depreciable assets sold after three years remain short-term capital gains under Section 50, taxable at normal rates. Dividend distribution tax under Section 115O applies regardless of recipient residency. Lease premium deduction was allowed following Balmer Lawrie precedent. Case-Laws Income Tax Fri, 27 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447752