https://www.taxtmi.com/caselaws?id=448144 The ITAT Mumbai allowed the assessee's appeal on transfer pricing adjustment for corporate guarantee, finding that internal CUP at 0.65% from IDBI and ICICI banks based on actual exposure was more reliable than external CUP from other banks obtained through general inquiries. Several issues including forward contract gains, doubtful debt provisions, accounting standard adjustments, section 69C additions for unexplained sales, double taxation relief, and dividend distribution tax credit were remitted back to AO for verification with proper documentation. The section 14A disallowance was corrected from Rs. 60,35,270 to Rs. 6,35,270 due to clerical error. en-us Tue, 31 Oct 2023 00:00:00 +0530 Fri, 12 Jan 2024 08:41:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448144 The ITAT Mumbai allowed the assessee's appeal on transfer pricing adjustment for corporate guarantee, finding that internal CUP at 0.65% from IDBI and ICICI banks based on actual exposure was more reliable than external CUP from other banks obtained through general inquiries. Several issues including forward contract gains, doubtful debt provisions, accounting standard adjustments, section 69C additions for unexplained sales, double taxation relief, and dividend distribution tax credit were remitted back to AO for verification with proper documentation. The section 14A disallowance was corrected from Rs. 60,35,270 to Rs. 6,35,270 due to clerical error. Case-Laws Income Tax Tue, 31 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448144