https://www.taxtmi.com/caselaws?id=449072 ITAT Ahmedabad ruled on multiple transfer pricing and tax issues. The tribunal rejected the assessee's claim that advances to Associated Enterprises were quasi-capital in nature, holding that advance nature must be determined at the time of granting, not subsequent conversion to equity. The matter was remanded to CIT(A) to determine correct interest rates. The tribunal deleted additions for alleged profit diversion from partnership firm to assessee company, finding no concrete evidence of diversion. Various deductions under Section 35(2AB) for R&D expenses were partially allowed. Corporate guarantee fees at 0.8% were upheld as justified. Several other disallowances under Sections 14A, 36(1)(iii), and 40A(2)(b) were deleted, while some matters were restored to AO for fresh consideration. en-us Wed, 31 Jan 2024 00:00:00 +0530 Mon, 11 Nov 2024 10:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449072 ITAT Ahmedabad ruled on multiple transfer pricing and tax issues. The tribunal rejected the assessee's claim that advances to Associated Enterprises were quasi-capital in nature, holding that advance nature must be determined at the time of granting, not subsequent conversion to equity. The matter was remanded to CIT(A) to determine correct interest rates. The tribunal deleted additions for alleged profit diversion from partnership firm to assessee company, finding no concrete evidence of diversion. Various deductions under Section 35(2AB) for R&D expenses were partially allowed. Corporate guarantee fees at 0.8% were upheld as justified. Several other disallowances under Sections 14A, 36(1)(iii), and 40A(2)(b) were deleted, while some matters were restored to AO for fresh consideration. Case-Laws Income Tax Wed, 31 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449072