https://www.taxtmi.com/caselaws?id=762906 The ITAT Delhi upheld CIT(A)'s decision deleting transfer pricing adjustments on loan interest rates, finding that the associated enterprise paid higher rates (11-13%) than applicable LIBOR rate (5.4%), making the adjustment unjustified. The tribunal also deleted additions for corporate guarantee commission, ruling it doesn't constitute an international transaction under section 92. Additionally, disallowance under section 14A was deleted as the assessee had sufficient interest-free funds exceeding investments, presuming investments were made from own funds rather than borrowed funds. The delayed TDS deposit addition under section 40(a) was also deleted as TDS was deposited within specified time. en-us Thu, 19 Sep 2024 00:00:00 +0530 Mon, 09 Dec 2024 12:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762906 The ITAT Delhi upheld CIT(A)'s decision deleting transfer pricing adjustments on loan interest rates, finding that the associated enterprise paid higher rates (11-13%) than applicable LIBOR rate (5.4%), making the adjustment unjustified. The tribunal also deleted additions for corporate guarantee commission, ruling it doesn't constitute an international transaction under section 92. Additionally, disallowance under section 14A was deleted as the assessee had sufficient interest-free funds exceeding investments, presuming investments were made from own funds rather than borrowed funds. The delayed TDS deposit addition under section 40(a) was also deleted as TDS was deposited within specified time. Case-Laws Income Tax Thu, 19 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762906