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    <title>2024 (11) TMI 1092 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai allowed the appeal for statistical purposes. The tribunal deleted the addition of INR 406.51 crores under Section 14A/Rule 8D(2)(ii) as the appellant had sufficient interest-free funds for tax-free investments. Disallowance under Rule 8D(2)(iii) was directed for recomputation considering only exempt income investments. The tribunal deleted adjustment to book profits under Section 115JB and disallowance under Section 40(a)(ia) for prepaid distributor discounts, following previous decisions. Depreciation on 3G spectrum was allowed under Section 32(1)(ii). Transfer pricing adjustments for brand royalty and expense reimbursements were remanded to TPO/AO for fresh consideration. Additional TDS credit was directed to be verified and granted.</description>
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    <pubDate>Tue, 22 Oct 2024 00:00:00 +0530</pubDate>
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      <title>2024 (11) TMI 1092 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=762106</link>
      <description>ITAT Mumbai allowed the appeal for statistical purposes. The tribunal deleted the addition of INR 406.51 crores under Section 14A/Rule 8D(2)(ii) as the appellant had sufficient interest-free funds for tax-free investments. Disallowance under Rule 8D(2)(iii) was directed for recomputation considering only exempt income investments. The tribunal deleted adjustment to book profits under Section 115JB and disallowance under Section 40(a)(ia) for prepaid distributor discounts, following previous decisions. Depreciation on 3G spectrum was allowed under Section 32(1)(ii). Transfer pricing adjustments for brand royalty and expense reimbursements were remanded to TPO/AO for fresh consideration. Additional TDS credit was directed to be verified and granted.</description>
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      <pubDate>Tue, 22 Oct 2024 00:00:00 +0530</pubDate>
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