https://www.taxtmi.com/caselaws?id=461352 ITAT Chennai ruled on multiple issues in this transfer pricing and tax matter. The tribunal partially allowed the Revenue's appeal, directing the AO to assess corporate guarantee commission at 0.5% instead of 1% as determined by the TPO, following the Everest Kento Cylinder Ltd precedent. The tribunal dismissed Revenue's challenge to additional depreciation claims for assets used less than 180 days, upholding the CIT(A)'s decision based on Madras HC ruling. Regarding section 14A disallowances, the tribunal remanded the matter to AO for verification of whether the assessee had sufficient own funds for investments, noting the HDFC Ltd precedent. The tribunal also directed AO to consider only dividend-yielding investments for Rule 8D(2)(iii) disallowance calculations. en-us Fri, 20 Oct 2023 00:00:00 +0530 Mon, 31 Mar 2025 12:23:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461352 ITAT Chennai ruled on multiple issues in this transfer pricing and tax matter. The tribunal partially allowed the Revenue's appeal, directing the AO to assess corporate guarantee commission at 0.5% instead of 1% as determined by the TPO, following the Everest Kento Cylinder Ltd precedent. The tribunal dismissed Revenue's challenge to additional depreciation claims for assets used less than 180 days, upholding the CIT(A)'s decision based on Madras HC ruling. Regarding section 14A disallowances, the tribunal remanded the matter to AO for verification of whether the assessee had sufficient own funds for investments, noting the HDFC Ltd precedent. The tribunal also directed AO to consider only dividend-yielding investments for Rule 8D(2)(iii) disallowance calculations. Case-Laws Income Tax Fri, 20 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461352