https://www.taxtmi.com/caselaws?id=460387 The ITAT Chennai ruled on multiple issues in a transfer pricing case. For international transactions, the tribunal remanded the interest-free loan issue to verify surplus funds and nexus with borrowings, while reducing corporate guarantee fee adjustment from 1.5% to 0.5% following HC precedents. The tribunal allowed foreign exchange losses on ECB loans used for domestic assets as revenue expenditure, following SC precedent in Wipro Finance. Software expenses and leasehold land amortization were remanded for factual verification. Interest on diverted funds was deleted as the assessee had sufficient own funds. DDT credit discrepancy and interest computation under section 234A were remanded for verification. Section 35(2AB) deduction was allowed following earlier year's ratio, while section 43B disallowance for leave salary was upheld per SC ruling in Exide Industries. Section 14A disallowance was restricted to investments yielding exempt income only. en-us Fri, 08 Nov 2024 00:00:00 +0530 Tue, 21 Jan 2025 15:01:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460387 The ITAT Chennai ruled on multiple issues in a transfer pricing case. For international transactions, the tribunal remanded the interest-free loan issue to verify surplus funds and nexus with borrowings, while reducing corporate guarantee fee adjustment from 1.5% to 0.5% following HC precedents. The tribunal allowed foreign exchange losses on ECB loans used for domestic assets as revenue expenditure, following SC precedent in Wipro Finance. Software expenses and leasehold land amortization were remanded for factual verification. Interest on diverted funds was deleted as the assessee had sufficient own funds. DDT credit discrepancy and interest computation under section 234A were remanded for verification. Section 35(2AB) deduction was allowed following earlier year's ratio, while section 43B disallowance for leave salary was upheld per SC ruling in Exide Industries. Section 14A disallowance was restricted to investments yielding exempt income only. Case-Laws Income Tax Fri, 08 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460387