https://www.taxtmi.com/caselaws?id=460379 ITAT Chennai set aside lower authorities' orders on TP adjustment regarding interest-free loan to subsidiary, directing AO to verify assessee's surplus funds and nexus between borrowed funds and advance to UK Associate Enterprise. Tribunal upheld disallowance under section 14A read with Rule 8D for expenditure related to dividend income, finding borrowed and interest-free funds formed common pool. Software expenditure capitalization was confirmed, with DRP directing verification of permanent versus temporary nature. Additional depreciation claim of 10% for machinery was allowed following Apollo Tyres precedent. Issues regarding total income recording errors and TDS/TCS credit verification were remitted back to AO for reconsideration. Appeal partly allowed. en-us Fri, 04 Mar 2016 00:00:00 +0530 Tue, 21 Jan 2025 19:07:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460379 ITAT Chennai set aside lower authorities' orders on TP adjustment regarding interest-free loan to subsidiary, directing AO to verify assessee's surplus funds and nexus between borrowed funds and advance to UK Associate Enterprise. Tribunal upheld disallowance under section 14A read with Rule 8D for expenditure related to dividend income, finding borrowed and interest-free funds formed common pool. Software expenditure capitalization was confirmed, with DRP directing verification of permanent versus temporary nature. Additional depreciation claim of 10% for machinery was allowed following Apollo Tyres precedent. Issues regarding total income recording errors and TDS/TCS credit verification were remitted back to AO for reconsideration. Appeal partly allowed. Case-Laws Income Tax Fri, 04 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460379