https://www.taxtmi.com/caselaws?id=313911 ITAT Mumbai ruled in favor of the assessee on multiple transfer pricing issues. The tribunal deleted interest adjustments on advances to joint venture partners, holding these were capital contributions to protect business interests rather than loans requiring interest charges. Following precedent, guarantee fee adjustments were confirmed at 0.6% for recovered fees and 0.20% for unrecovered fees. The tribunal upheld deletion of foreign exchange mark-to-market loss additions, treating them as allowable accrued losses. Section 14A disallowance under section 115JB was also deleted as no exempt income was received. en-us Mon, 04 Dec 2023 00:00:00 +0530 Tue, 07 May 2024 23:06:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313911 ITAT Mumbai ruled in favor of the assessee on multiple transfer pricing issues. The tribunal deleted interest adjustments on advances to joint venture partners, holding these were capital contributions to protect business interests rather than loans requiring interest charges. Following precedent, guarantee fee adjustments were confirmed at 0.6% for recovered fees and 0.20% for unrecovered fees. The tribunal upheld deletion of foreign exchange mark-to-market loss additions, treating them as allowable accrued losses. Section 14A disallowance under section 115JB was also deleted as no exempt income was received. Case-Laws Income Tax Mon, 04 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313911