https://www.taxtmi.com/caselaws?id=753752 ITAT Ahmedabad upheld CIT(A)'s decision restricting transfer pricing adjustment for guarantee commission to 0.2% instead of AO's 0.77%, finding TPO incorrectly benchmarked 822-day transaction against 365-day rate and applied unjustified 0.25% markup. Court allowed ESOP expense deduction under section 37(1), treating employee share discount as ascertained business liability for securing services, not capital expenditure. Section 14A disallowance was deleted as assessee earned no exempt income during the year, following Supreme Court precedents in State Bank of Patiala and Chettinad Logistics cases. Revenue's appeal dismissed on all grounds. en-us Tue, 04 Jun 2024 00:00:00 +0530 Sat, 08 Jun 2024 09:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753752 ITAT Ahmedabad upheld CIT(A)'s decision restricting transfer pricing adjustment for guarantee commission to 0.2% instead of AO's 0.77%, finding TPO incorrectly benchmarked 822-day transaction against 365-day rate and applied unjustified 0.25% markup. Court allowed ESOP expense deduction under section 37(1), treating employee share discount as ascertained business liability for securing services, not capital expenditure. Section 14A disallowance was deleted as assessee earned no exempt income during the year, following Supreme Court precedents in State Bank of Patiala and Chettinad Logistics cases. Revenue's appeal dismissed on all grounds. Case-Laws Income Tax Tue, 04 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753752