https://www.taxtmi.com/caselaws?id=313071 ITAT Mumbai held that corporate guarantee fee determination requires case-specific analysis using interest saving approach rather than standard 0.5% rate. Matter remanded to AO/TPO for proper benchmarking. Section 14A disallowance restricted to investments yielding exempt income only. Interest income from ECB surplus deposits treated as capital receipt, not revenue, being inextricably linked to plant setup. Additional depreciation under section 32(1)(ii) allowed as third proviso deemed clarificatory and applicable retrospectively per jurisdictional HC precedent. en-us Mon, 04 Dec 2023 00:00:00 +0530 Fri, 22 Mar 2024 06:57:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313071 ITAT Mumbai held that corporate guarantee fee determination requires case-specific analysis using interest saving approach rather than standard 0.5% rate. Matter remanded to AO/TPO for proper benchmarking. Section 14A disallowance restricted to investments yielding exempt income only. Interest income from ECB surplus deposits treated as capital receipt, not revenue, being inextricably linked to plant setup. Additional depreciation under section 32(1)(ii) allowed as third proviso deemed clarificatory and applicable retrospectively per jurisdictional HC precedent. Case-Laws Income Tax Mon, 04 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313071