https://www.taxtmi.com/caselaws?id=768068 ITAT Chennai partly allowed appellant's appeal regarding multiple transfer pricing and tax issues. For corporate guarantee commission, tribunal reduced rate from 2% to 0.5% following precedent. On brand promotion expenses, matter was remanded to AO/TPO for fresh examination after Delhi HC held revenue must establish international transaction before benchmarking. Royalty adjustment was upheld as income under mercantile accounting. Section 14A disallowance was deleted where own funds exceeded investments, but partial disallowance under Rule 8D(2)(iii) was directed for dividend-yielding investments only. Export commission disallowance was deleted following earlier tribunal decision. Foreign exchange losses and forward contract premiums were allowed as revenue expenditure. Additional depreciation claim for balance amount was permitted in subsequent year. en-us Fri, 24 Jan 2025 00:00:00 +0530 Mon, 31 Mar 2025 08:41:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768068 ITAT Chennai partly allowed appellant's appeal regarding multiple transfer pricing and tax issues. For corporate guarantee commission, tribunal reduced rate from 2% to 0.5% following precedent. On brand promotion expenses, matter was remanded to AO/TPO for fresh examination after Delhi HC held revenue must establish international transaction before benchmarking. Royalty adjustment was upheld as income under mercantile accounting. Section 14A disallowance was deleted where own funds exceeded investments, but partial disallowance under Rule 8D(2)(iii) was directed for dividend-yielding investments only. Export commission disallowance was deleted following earlier tribunal decision. Foreign exchange losses and forward contract premiums were allowed as revenue expenditure. Additional depreciation claim for balance amount was permitted in subsequent year. Case-Laws Income Tax Fri, 24 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768068