https://www.taxtmi.com/caselaws?id=460403 The ITAT Chennai upheld the reopening of assessment under section 147 as the assessee failed to file AE transaction details in Form 3CEB. For guarantee commission adjustments, following Redington India Ltd precedent, disallowance was restricted to 0.5% of guarantee value. Section 14A disallowance issues were remitted to AO for verification of interest-free funds versus exempt income investments. Interest expenditure disallowance on subsidiary advances was restored to AO following Reliance Industries SC decision. Software expenses were partially allowed - recurring expenses as revenue, permanent licenses as capital expenditure. TDS issues under section 40(a)(ia) were remitted for re-examination per Faizan Shoes HC ruling. Additional depreciation claim for balance 50% was allowed following tribunal's own precedent for AY 2010-11. en-us Thu, 31 Aug 2023 00:00:00 +0530 Wed, 22 Jan 2025 18:57:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460403 The ITAT Chennai upheld the reopening of assessment under section 147 as the assessee failed to file AE transaction details in Form 3CEB. For guarantee commission adjustments, following Redington India Ltd precedent, disallowance was restricted to 0.5% of guarantee value. Section 14A disallowance issues were remitted to AO for verification of interest-free funds versus exempt income investments. Interest expenditure disallowance on subsidiary advances was restored to AO following Reliance Industries SC decision. Software expenses were partially allowed - recurring expenses as revenue, permanent licenses as capital expenditure. TDS issues under section 40(a)(ia) were remitted for re-examination per Faizan Shoes HC ruling. Additional depreciation claim for balance 50% was allowed following tribunal's own precedent for AY 2010-11. Case-Laws Income Tax Thu, 31 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460403