https://www.taxtmi.com/caselaws?id=314418 ITAT Mumbai ruled in favor of the assessee on multiple issues. The tribunal held that transfer pricing provisions do not apply to share application money where no income accrues, following precedent from Shell India Markets case. The court allowed 1/5th deduction of FCCB issue expenses under section 35D, reversing AO's disallowance. Regarding section 14A disallowance, the tribunal deleted both AO's addition and assessee's suo-moto disallowance since no exempt income was derived, also directing corresponding adjustment to book profit under section 115JB. The AO was directed to examine and allow set-off of brought forward long-term capital losses against current year's long-term capital gains as per law. en-us Wed, 28 Jun 2023 00:00:00 +0530 Fri, 07 Jun 2024 20:46:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314418 ITAT Mumbai ruled in favor of the assessee on multiple issues. The tribunal held that transfer pricing provisions do not apply to share application money where no income accrues, following precedent from Shell India Markets case. The court allowed 1/5th deduction of FCCB issue expenses under section 35D, reversing AO's disallowance. Regarding section 14A disallowance, the tribunal deleted both AO's addition and assessee's suo-moto disallowance since no exempt income was derived, also directing corresponding adjustment to book profit under section 115JB. The AO was directed to examine and allow set-off of brought forward long-term capital losses against current year's long-term capital gains as per law. Case-Laws Income Tax Wed, 28 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314418