https://www.taxtmi.com/caselaws?id=755177 ITAT Ahmedabad ruled on multiple issues in a transfer pricing case. The tribunal deleted TP adjustments for interest on loans to associated enterprises, finding the TPO incorrectly calculated interest for the entire 180-day period when loans were advanced in installments. Corporate guarantee fee adjustment was restricted to 0.5% based on banking commission rates. The tribunal upheld CIT(A)'s deletion of disallowances under section 36(1)(iii) for interest-free advances, confirming sufficient interest-free funds existed. Weighted deduction under section 35(2AB) at 150% for R&D expenses was allowed, with product registration expenses treated as revenue expenditure. The tribunal dismissed revenue's appeals on section 14A disallowance restriction and foreign exchange loss treatment as business loss rather than speculation loss. en-us Mon, 01 Jul 2024 00:00:00 +0530 Sat, 06 Jul 2024 07:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755177 ITAT Ahmedabad ruled on multiple issues in a transfer pricing case. The tribunal deleted TP adjustments for interest on loans to associated enterprises, finding the TPO incorrectly calculated interest for the entire 180-day period when loans were advanced in installments. Corporate guarantee fee adjustment was restricted to 0.5% based on banking commission rates. The tribunal upheld CIT(A)'s deletion of disallowances under section 36(1)(iii) for interest-free advances, confirming sufficient interest-free funds existed. Weighted deduction under section 35(2AB) at 150% for R&D expenses was allowed, with product registration expenses treated as revenue expenditure. The tribunal dismissed revenue's appeals on section 14A disallowance restriction and foreign exchange loss treatment as business loss rather than speculation loss. Case-Laws Income Tax Mon, 01 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755177