https://www.taxtmi.com/caselaws?id=314406 ITAT Mumbai held that TPO's rejection of Cost Plus Method (CPM) in favor of Transactional Net Margin Method (TNMM) was unjustified when complete books were produced, directing acceptance of CPM as most appropriate method. Corporate guarantees to associated enterprises constitute international transactions under Section 92B, with arm's length price fixed at 0.5% per annum. Tribunal allowed deductions under Section 10B for export profits and Section 35(2AB) for R&D expenses, following previous orders in assessee's own case. Various disallowances including rental expenditure, FCCB premium, and Section 14A were deleted or remanded for re-computation based on coordinate bench precedents. en-us Fri, 02 Sep 2022 00:00:00 +0530 Thu, 06 Jun 2024 20:09:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314406 ITAT Mumbai held that TPO's rejection of Cost Plus Method (CPM) in favor of Transactional Net Margin Method (TNMM) was unjustified when complete books were produced, directing acceptance of CPM as most appropriate method. Corporate guarantees to associated enterprises constitute international transactions under Section 92B, with arm's length price fixed at 0.5% per annum. Tribunal allowed deductions under Section 10B for export profits and Section 35(2AB) for R&D expenses, following previous orders in assessee's own case. Various disallowances including rental expenditure, FCCB premium, and Section 14A were deleted or remanded for re-computation based on coordinate bench precedents. Case-Laws Income Tax Fri, 02 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314406