https://www.taxtmi.com/highlights?id=84087 The Income Tax Appellate Tribunal ruled as follows: Transfer pricing adjustment u/s 92CA(3) for determining arm's length price on interest paid to a related party was deleted. As the order was passed after April 1, 2017, it is covered by the ratio of M/s Texport case, and the addition treating the transaction as a specified domestic transaction is unsustainable. The disallowance u/s 40A(3) for cash payment of Rs. 8,00,000/- to villagers was upheld. The applicability of Section 40A(3) would exclude only cases covered u/r 6DD, and the genuineness of parties or payments was not doubted. The ad-hoc disallowance of 5% on various expenses like travel, promotion, lodging, and pooja expenses was upheld. Since the expenses were supported by self-mad..... en-us Wed, 18 Dec 2024 08:58:08 +0530 Wed, 18 Dec 2024 08:58:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=84087 The Income Tax Appellate Tribunal ruled as follows: Transfer pricing adjustment u/s 92CA(3) for determining arm's length price on interest paid to a related party was deleted. As the order was passed after April 1, 2017, it is covered by the ratio of M/s Texport case, and the addition treating the transaction as a specified domestic transaction is unsustainable. The disallowance u/s 40A(3) for cash payment of Rs. 8,00,000/- to villagers was upheld. The applicability of Section 40A(3) would exclude only cases covered u/r 6DD, and the genuineness of parties or payments was not doubted. The ad-hoc disallowance of 5% on various expenses like travel, promotion, lodging, and pooja expenses was upheld. Since the expenses were supported by self-mad..... Highlights Income Tax Wed, 18 Dec 2024 08:58:08 +0530 https://www.taxtmi.com/highlights?id=84087