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    <title>2024 (7) TMI 1126 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai ruled on multiple transfer pricing and tax issues. For NCCRPS transactions, the tribunal directed benchmarking against 3-year LIBOR rate plus basis points rather than domestic rates, considering it as quasi-capital financing. On finance lease accounting, the tribunal clarified that lessees should claim depreciation per IT Act rather than principal repayments, remitting the matter for verification. ESOP expenses were allowed as deductions following Karnataka HC precedent in Biocon Ltd. Section 14A disallowance was remitted for recalculation considering only investments yielding exempt income. The tribunal deleted Section 14A adjustment from book profit under Section 115JB. Cash deposits during demonetization were remitted for verification given assessee&#039;s authorized dealer status. Depreciation on reoccupied property was allowed after tenant surrender. Indexation benefit for book profit computation was permitted following Karnataka HC precedent.</description>
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    <pubDate>Fri, 24 Nov 2023 00:00:00 +0530</pubDate>
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      <description>ITAT Mumbai ruled on multiple transfer pricing and tax issues. For NCCRPS transactions, the tribunal directed benchmarking against 3-year LIBOR rate plus basis points rather than domestic rates, considering it as quasi-capital financing. On finance lease accounting, the tribunal clarified that lessees should claim depreciation per IT Act rather than principal repayments, remitting the matter for verification. ESOP expenses were allowed as deductions following Karnataka HC precedent in Biocon Ltd. Section 14A disallowance was remitted for recalculation considering only investments yielding exempt income. The tribunal deleted Section 14A adjustment from book profit under Section 115JB. Cash deposits during demonetization were remitted for verification given assessee&#039;s authorized dealer status. Depreciation on reoccupied property was allowed after tenant surrender. Indexation benefit for book profit computation was permitted following Karnataka HC precedent.</description>
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