https://www.taxtmi.com/caselaws?id=451162 The ITAT Delhi ruled on multiple issues in this transfer pricing case. For corporate guarantee fees, the tribunal reduced the TPO's 75% interest benefit allocation to a 50:50 split between guarantor and borrower. On royalty adjustments, it set rates at nil for one AE and 0.75% for another. The tribunal deleted additions for ESI/EPF delays, audit report-based additions under section 43B, and accounting policy changes, finding no valid basis for these adjustments. It upheld CIT(A)'s deletion of notional interest on trade receivables and section 14A additions where no exempt income existed. The deduction under section 80G was remanded to AO for fresh consideration after proper evidence review. en-us Mon, 18 Mar 2024 00:00:00 +0530 Wed, 20 Mar 2024 12:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=451162 The ITAT Delhi ruled on multiple issues in this transfer pricing case. For corporate guarantee fees, the tribunal reduced the TPO's 75% interest benefit allocation to a 50:50 split between guarantor and borrower. On royalty adjustments, it set rates at nil for one AE and 0.75% for another. The tribunal deleted additions for ESI/EPF delays, audit report-based additions under section 43B, and accounting policy changes, finding no valid basis for these adjustments. It upheld CIT(A)'s deletion of notional interest on trade receivables and section 14A additions where no exempt income existed. The deduction under section 80G was remanded to AO for fresh consideration after proper evidence review. Case-Laws Income Tax Mon, 18 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=451162