https://www.taxtmi.com/caselaws?id=766581 ITAT Mumbai upheld CIT(A)'s decision deleting transfer pricing adjustment on guarantee fee. Assessee determined arm's length price at 0.41% per annum for corporate guarantee to associated enterprises, supported by bank facility letter showing 0.30% rate. TPO's 1.25% rate lacked supporting material and improperly relied on overturned DRP order from previous year. Court found TPO failed to conduct yearly factual exercise for ALP determination. Regarding Section 14A disallowance, ITAT confirmed CIT(A)'s restriction to assessee's suo moto disallowance on exempt dividend income from mutual fund investments, noting AO failed to record dissatisfaction with assessee's methodology before invoking Rule 8D. en-us Thu, 30 Jan 2025 00:00:00 +0530 Fri, 28 Feb 2025 08:23:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766581 ITAT Mumbai upheld CIT(A)'s decision deleting transfer pricing adjustment on guarantee fee. Assessee determined arm's length price at 0.41% per annum for corporate guarantee to associated enterprises, supported by bank facility letter showing 0.30% rate. TPO's 1.25% rate lacked supporting material and improperly relied on overturned DRP order from previous year. Court found TPO failed to conduct yearly factual exercise for ALP determination. Regarding Section 14A disallowance, ITAT confirmed CIT(A)'s restriction to assessee's suo moto disallowance on exempt dividend income from mutual fund investments, noting AO failed to record dissatisfaction with assessee's methodology before invoking Rule 8D. Case-Laws Income Tax Thu, 30 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766581