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    <title>2024 (2) TMI 1279 - ITAT AHMEDABAD</title>
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    <description>The ITAT Ahmedabad ruled in favor of the assessee on multiple transfer pricing and tax issues. The tribunal deleted TP adjustments for corporate guarantee charges, holding that 1% rate was at arm&#039;s length based on previous years&#039; decisions. TP adjustments on optionally convertible loans were deleted as they were deemed quasi-capital in nature. Reimbursement expense adjustments were also deleted following precedent. The tribunal allowed product registration expenses as revenue expenditure and granted weighted deduction under section 35(2AB) for clinical trials. Additionally, disallowance under section 14A was deleted from book profits under section 115JB, following the Vireet Investments precedent.</description>
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      <link>https://www.taxtmi.com/caselaws?id=450128</link>
      <description>The ITAT Ahmedabad ruled in favor of the assessee on multiple transfer pricing and tax issues. The tribunal deleted TP adjustments for corporate guarantee charges, holding that 1% rate was at arm&#039;s length based on previous years&#039; decisions. TP adjustments on optionally convertible loans were deleted as they were deemed quasi-capital in nature. Reimbursement expense adjustments were also deleted following precedent. The tribunal allowed product registration expenses as revenue expenditure and granted weighted deduction under section 35(2AB) for clinical trials. Additionally, disallowance under section 14A was deleted from book profits under section 115JB, following the Vireet Investments precedent.</description>
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