https://www.taxtmi.com/caselaws?id=753853 ITAT Ahmedabad allowed the assessee's appeal on multiple grounds. The tribunal deleted disallowances of Annual Technical Service fees and bank guarantee commission additions, following consistent precedents from previous years where identical issues were decided favorably. The disallowance under Section 14A was deleted as the AO failed to satisfy prerequisites before invoking Rule 8D, given the assessee's scientific calculation method. Interest on NPAs addition was also deleted based on prior favorable decisions. The Employee Stock Option cost issue was restored to AO for fresh decision per prevailing law. For transfer pricing adjustment on international transactions, the tribunal rejected equating Letters of Comfort with bank guarantees but directed AO to apply safe harbor rules at LIBOR plus 400 basis points. en-us Wed, 10 Apr 2024 00:00:00 +0530 Tue, 11 Jun 2024 12:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753853 ITAT Ahmedabad allowed the assessee's appeal on multiple grounds. The tribunal deleted disallowances of Annual Technical Service fees and bank guarantee commission additions, following consistent precedents from previous years where identical issues were decided favorably. The disallowance under Section 14A was deleted as the AO failed to satisfy prerequisites before invoking Rule 8D, given the assessee's scientific calculation method. Interest on NPAs addition was also deleted based on prior favorable decisions. The Employee Stock Option cost issue was restored to AO for fresh decision per prevailing law. For transfer pricing adjustment on international transactions, the tribunal rejected equating Letters of Comfort with bank guarantees but directed AO to apply safe harbor rules at LIBOR plus 400 basis points. Case-Laws Income Tax Wed, 10 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753853