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    <title>2024 (6) TMI 354 - ITAT MUMBAI</title>
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    <description>Share application money could not be re-characterised as a loan for charging interest where the facts were identical to the assessee&#039;s earlier year, so the transfer-pricing adjustment was deleted. Employees&#039; contribution to PF and ESIC turned on verification of the claimed grace period, and the matter was sent back for factual examination with relief available if payment was timely. No disallowance under section 14A was called for in the absence of exempt income, and such an adjustment could not be added to book profit under section 115JB, so that addition was deleted. Short TDS credit and interest under sections 234B and 234C were also remitted for fresh verification.</description>
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      <link>https://www.taxtmi.com/caselaws?id=753747</link>
      <description>Share application money could not be re-characterised as a loan for charging interest where the facts were identical to the assessee&#039;s earlier year, so the transfer-pricing adjustment was deleted. Employees&#039; contribution to PF and ESIC turned on verification of the claimed grace period, and the matter was sent back for factual examination with relief available if payment was timely. No disallowance under section 14A was called for in the absence of exempt income, and such an adjustment could not be added to book profit under section 115JB, so that addition was deleted. Short TDS credit and interest under sections 234B and 234C were also remitted for fresh verification.</description>
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