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    <title>2024 (1) TMI 1291 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai ruled in favor of the assessee on multiple issues. The tribunal held that no transfer pricing adjustment for interest on delayed export receivables from associated enterprises was warranted, as the assessee uniformly did not charge interest from both AEs and non-AEs for payment delays. The court deleted additions for notional interest on share application money, ruling that such transactions cannot be recharacterized as loans and represent capital account transactions. FCCB issue expenses were allowed to be amortized over five years as previously permitted. Disallowances under section 14A were deleted since no exempt income was earned during the relevant period.</description>
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      <title>2024 (1) TMI 1291 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=314424</link>
      <description>The ITAT Mumbai ruled in favor of the assessee on multiple issues. The tribunal held that no transfer pricing adjustment for interest on delayed export receivables from associated enterprises was warranted, as the assessee uniformly did not charge interest from both AEs and non-AEs for payment delays. The court deleted additions for notional interest on share application money, ruling that such transactions cannot be recharacterized as loans and represent capital account transactions. FCCB issue expenses were allowed to be amortized over five years as previously permitted. Disallowances under section 14A were deleted since no exempt income was earned during the relevant period.</description>
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      <pubDate>Mon, 15 Jan 2024 00:00:00 +0530</pubDate>
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