https://www.taxtmi.com/caselaws?id=752431 ITAT Mumbai ruled on multiple transfer pricing and tax credit issues. The tribunal held corporate guarantees constitute international transactions requiring ALP benchmarking at 0.20% rate. Regarding Kenya tax credit denial, the tribunal found Rule 128 (effective 2017) cannot apply retrospectively to 2015 returns and remanded for verification. TDS credit denial was also remanded for proper verification of income attribution. Section 14A disallowance under 115JB was decided favorably for assessee following precedent, as no exempt income was received. Business advances to South Africa JV were deemed capital contributions protecting business interests, not loans requiring TP adjustment. Guarantee commission rate was increased from 0.2% to 0.6% following coordinate bench precedent. en-us Fri, 03 May 2024 00:00:00 +0530 Thu, 09 May 2024 08:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752431 ITAT Mumbai ruled on multiple transfer pricing and tax credit issues. The tribunal held corporate guarantees constitute international transactions requiring ALP benchmarking at 0.20% rate. Regarding Kenya tax credit denial, the tribunal found Rule 128 (effective 2017) cannot apply retrospectively to 2015 returns and remanded for verification. TDS credit denial was also remanded for proper verification of income attribution. Section 14A disallowance under 115JB was decided favorably for assessee following precedent, as no exempt income was received. Business advances to South Africa JV were deemed capital contributions protecting business interests, not loans requiring TP adjustment. Guarantee commission rate was increased from 0.2% to 0.6% following coordinate bench precedent. Case-Laws Income Tax Fri, 03 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752431