https://www.taxtmi.com/caselaws?id=750619 ITAT Mumbai remanded three transfer pricing issues back to lower authorities for fresh determination. First, regarding corporate guarantee transactions to banks on behalf of associated enterprises, the tribunal directed the A.O. to determine arm's length price using interest saving approach following previous tribunal decisions. Second, for interest on loans advanced to AE, the tribunal found neither assessee nor authorities properly benchmarked the transaction - assessee charged 2% while A.O./TPO applied 10.68% and CIT(A) restricted to 5%. The matter was remanded to CIT(A) for proper benchmarking. Third, concerning Section 14A disallowance, the tribunal remanded to A.O. to restrict disallowance only to investments yielding exempt income and verify availability of interest-free funds, noting assessee had interest-free funds exceeding borrowed funds during the relevant year. en-us Wed, 20 Mar 2024 00:00:00 +0530 Sat, 23 Mar 2024 08:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=750619 ITAT Mumbai remanded three transfer pricing issues back to lower authorities for fresh determination. First, regarding corporate guarantee transactions to banks on behalf of associated enterprises, the tribunal directed the A.O. to determine arm's length price using interest saving approach following previous tribunal decisions. Second, for interest on loans advanced to AE, the tribunal found neither assessee nor authorities properly benchmarked the transaction - assessee charged 2% while A.O./TPO applied 10.68% and CIT(A) restricted to 5%. The matter was remanded to CIT(A) for proper benchmarking. Third, concerning Section 14A disallowance, the tribunal remanded to A.O. to restrict disallowance only to investments yielding exempt income and verify availability of interest-free funds, noting assessee had interest-free funds exceeding borrowed funds during the relevant year. Case-Laws Income Tax Wed, 20 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=750619