https://www.taxtmi.com/caselaws?id=769912 ITAT Mumbai dismissed Revenue's appeal and allowed assessee's cross-objection. Court upheld CIT(A)'s deletion of disallowance u/s 14A as assessing officer failed to record satisfaction regarding expenditure correctness. Notional interest disallowance u/s 36(1)(iii) was deleted since assessee had sufficient interest-free funds exceeding advances given. TP adjustment for financial guarantee was remanded to TPO for ALP determination, while performance guarantee adjustment was deleted as no fees would be required if assessee executed contracts using own funds. Letter of comfort deletion was confirmed as no contractual financial obligation was established. Book profit adjustment u/s 115JB was restricted to assessee's suo moto disallowance, following precedent that Rule 8D disallowances cannot be added to book profit computation. en-us Thu, 06 Mar 2025 00:00:00 +0530 Sat, 03 May 2025 08:34:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769912 ITAT Mumbai dismissed Revenue's appeal and allowed assessee's cross-objection. Court upheld CIT(A)'s deletion of disallowance u/s 14A as assessing officer failed to record satisfaction regarding expenditure correctness. Notional interest disallowance u/s 36(1)(iii) was deleted since assessee had sufficient interest-free funds exceeding advances given. TP adjustment for financial guarantee was remanded to TPO for ALP determination, while performance guarantee adjustment was deleted as no fees would be required if assessee executed contracts using own funds. Letter of comfort deletion was confirmed as no contractual financial obligation was established. Book profit adjustment u/s 115JB was restricted to assessee's suo moto disallowance, following precedent that Rule 8D disallowances cannot be added to book profit computation. Case-Laws Income Tax Thu, 06 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769912