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    <title>2024 (12) TMI 972 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai held in favor of the assessee on multiple transfer pricing and tax issues. The tribunal ruled no TP adjustment was warranted for correspondent banking activities, finding services were reciprocal in nature with no markup required. For marketing support services relating to ECBs, no adjustment was needed as commission income was already accepted at arm&#039;s length. The tribunal upheld CIT(A)&#039;s deletion of derivative marketing adjustments and interest benchmarking corrections. Employee separation expenses were allowed as business deductions under section 37. The tribunal partially allowed tax-free income issues, restricting disallowance to 1% of exempt income, and confirmed Nostro account maintenance charges were not subject to TDS provisions.</description>
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    <pubDate>Fri, 28 Jun 2024 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=763392</link>
      <description>ITAT Mumbai held in favor of the assessee on multiple transfer pricing and tax issues. The tribunal ruled no TP adjustment was warranted for correspondent banking activities, finding services were reciprocal in nature with no markup required. For marketing support services relating to ECBs, no adjustment was needed as commission income was already accepted at arm&#039;s length. The tribunal upheld CIT(A)&#039;s deletion of derivative marketing adjustments and interest benchmarking corrections. Employee separation expenses were allowed as business deductions under section 37. The tribunal partially allowed tax-free income issues, restricting disallowance to 1% of exempt income, and confirmed Nostro account maintenance charges were not subject to TDS provisions.</description>
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      <pubDate>Fri, 28 Jun 2024 00:00:00 +0530</pubDate>
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