https://www.taxtmi.com/caselaws?id=312279 ITAT Mumbai allowed the appeal partially. The tribunal held that section 14A disallowance should exclude tonnage tax income computation and investments with no exempt dividend income. No interest disallowance was warranted as own funds exceeded investment value. For MAT computation, section 14A disallowance need not be added back to book profits under section 115JB. The assessee's 1.15% guarantee fee rate for financial guarantees to associated enterprises was upheld as arm's length price. Performance guarantee benchmarking was remanded to AO for fresh determination following established precedent. en-us Wed, 13 Sep 2023 00:00:00 +0530 Fri, 09 Feb 2024 18:27:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312279 ITAT Mumbai allowed the appeal partially. The tribunal held that section 14A disallowance should exclude tonnage tax income computation and investments with no exempt dividend income. No interest disallowance was warranted as own funds exceeded investment value. For MAT computation, section 14A disallowance need not be added back to book profits under section 115JB. The assessee's 1.15% guarantee fee rate for financial guarantees to associated enterprises was upheld as arm's length price. Performance guarantee benchmarking was remanded to AO for fresh determination following established precedent. Case-Laws Income Tax Wed, 13 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312279