https://www.taxtmi.com/caselaws?id=312567 The ITAT Mumbai ruled against revenue on multiple transfer pricing and tax deduction issues. The tribunal held that corporate guarantee commission charges cannot be subjected to transfer pricing adjustments, distinguishing them from bank guarantees per Bombay HC precedent. Share buyback transactions at different rates were deemed genuine business practices not requiring notional interest charges. R&D expense allocation to 80-IB/80-IC units was rejected as expenses were for specific research purposes unrelated to qualifying units. TDS provisions under section 195 were held inapplicable to commercial laboratory testing services as they don't constitute technical services. The tribunal remanded weighted deduction claims under section 35(2AB) for fresh consideration and allowed deduction where Form 3CL was delayed by DSIR. en-us Fri, 05 Jan 2018 00:00:00 +0530 Mon, 26 Feb 2024 06:13:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312567 The ITAT Mumbai ruled against revenue on multiple transfer pricing and tax deduction issues. The tribunal held that corporate guarantee commission charges cannot be subjected to transfer pricing adjustments, distinguishing them from bank guarantees per Bombay HC precedent. Share buyback transactions at different rates were deemed genuine business practices not requiring notional interest charges. R&D expense allocation to 80-IB/80-IC units was rejected as expenses were for specific research purposes unrelated to qualifying units. TDS provisions under section 195 were held inapplicable to commercial laboratory testing services as they don't constitute technical services. The tribunal remanded weighted deduction claims under section 35(2AB) for fresh consideration and allowed deduction where Form 3CL was delayed by DSIR. Case-Laws Income Tax Fri, 05 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312567