https://www.taxtmi.com/caselaws?id=753302 ITAT Mumbai allowed assessee's withdrawal of transfer pricing grounds regarding royalty allocation adjustment following MAP resolution between Indian and UK Competent Authorities under Rule 44G(6). The tribunal dismissed grounds 2-6 based on CBDT communication dated 11.10.2023 confirming MAP agreement on R&D services transaction with UK associated enterprise. For Section 14A disallowance, ITAT partly allowed assessee's appeal, directing AO to restrict disallowance to extent of exempt income earned, following Bombay HC precedent in Nirved Traders case. en-us Tue, 09 Jan 2024 00:00:00 +0530 Wed, 29 May 2024 16:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753302 ITAT Mumbai allowed assessee's withdrawal of transfer pricing grounds regarding royalty allocation adjustment following MAP resolution between Indian and UK Competent Authorities under Rule 44G(6). The tribunal dismissed grounds 2-6 based on CBDT communication dated 11.10.2023 confirming MAP agreement on R&D services transaction with UK associated enterprise. For Section 14A disallowance, ITAT partly allowed assessee's appeal, directing AO to restrict disallowance to extent of exempt income earned, following Bombay HC precedent in Nirved Traders case. Case-Laws Income Tax Tue, 09 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753302