https://www.taxtmi.com/caselaws?id=750907 ITAT Mumbai ruled on multiple issues in this tax appeal. For section 14A disallowance, the matter was remanded to CIT(A) for fresh consideration following Rule 8D provisions, with the tribunal noting that investments in sister concerns must be considered for disallowance computation. Regarding book profit adjustment under section 115JB, the tribunal allowed the assessee's cross-objection, following precedent that separate mechanisms exist for such adjustments. The disallowance under section 36(1)(iii) for advances was deleted, finding the assessee's interest-free funds exceeded the advances given. The unexplained money addition for property sale was upheld as deleted by CIT(A), confirming the transaction occurred in 1999. For transfer pricing, performance guarantee ALP determination was confirmed as deleted since the guarantee expired, while finance guarantee was remanded to TPO for proper ALP determination using prescribed methods. en-us Thu, 28 Mar 2024 00:00:00 +0530 Wed, 03 Apr 2024 06:26:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=750907 ITAT Mumbai ruled on multiple issues in this tax appeal. For section 14A disallowance, the matter was remanded to CIT(A) for fresh consideration following Rule 8D provisions, with the tribunal noting that investments in sister concerns must be considered for disallowance computation. Regarding book profit adjustment under section 115JB, the tribunal allowed the assessee's cross-objection, following precedent that separate mechanisms exist for such adjustments. The disallowance under section 36(1)(iii) for advances was deleted, finding the assessee's interest-free funds exceeded the advances given. The unexplained money addition for property sale was upheld as deleted by CIT(A), confirming the transaction occurred in 1999. For transfer pricing, performance guarantee ALP determination was confirmed as deleted since the guarantee expired, while finance guarantee was remanded to TPO for proper ALP determination using prescribed methods. Case-Laws Income Tax Thu, 28 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=750907