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    <title>2025 (1) TMI 1053 - ITAT CHENNAI</title>
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    <description>ITAT Chennai partly allowed the appeal in a transfer pricing case. For interest-free loans to AE, the matter was remitted to AO to verify surplus funds and nexus between borrowed loans and advances. Corporate guarantee fees were benchmarked at 0.5% instead of TPO&#039;s 2.55%. Depreciation on leasehold rights was remitted for fresh consideration. Section 80G deduction for CSR expenses was remitted for de novo adjudication. Section 14A disallowance was directed to consider only investments yielding exempt income. Interest on debentures was to be benchmarked using international comparable transactions rather than domestic rates.</description>
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    <pubDate>Wed, 15 Jan 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=764989</link>
      <description>ITAT Chennai partly allowed the appeal in a transfer pricing case. For interest-free loans to AE, the matter was remitted to AO to verify surplus funds and nexus between borrowed loans and advances. Corporate guarantee fees were benchmarked at 0.5% instead of TPO&#039;s 2.55%. Depreciation on leasehold rights was remitted for fresh consideration. Section 80G deduction for CSR expenses was remitted for de novo adjudication. Section 14A disallowance was directed to consider only investments yielding exempt income. Interest on debentures was to be benchmarked using international comparable transactions rather than domestic rates.</description>
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