https://www.taxtmi.com/caselaws?id=771133 The ITAT Mumbai held that transfer pricing provisions do not apply to qualifying ships under the tonnage tax scheme, following coordinate bench decisions and SC precedent in Trans Asian Shipping. The tribunal allowed relief for TP adjustments on lease loan interest from qualifying assets, noting tonnage tax provisions override general business profit computation rules. However, the corporate guarantee commission issue was remanded to TPO/AO for proper ALP determination using prescribed methods rather than adhoc rates. The tribunal dismissed the assessee's appeal regarding characterization of income tax refund interest, holding it remains "income from other sources" under Section 244A, not business income, as it compensates for revenue's delay in refunding excess tax. en-us Fri, 16 May 2025 00:00:00 +0530 Wed, 21 May 2025 08:29:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771133 The ITAT Mumbai held that transfer pricing provisions do not apply to qualifying ships under the tonnage tax scheme, following coordinate bench decisions and SC precedent in Trans Asian Shipping. The tribunal allowed relief for TP adjustments on lease loan interest from qualifying assets, noting tonnage tax provisions override general business profit computation rules. However, the corporate guarantee commission issue was remanded to TPO/AO for proper ALP determination using prescribed methods rather than adhoc rates. The tribunal dismissed the assessee's appeal regarding characterization of income tax refund interest, holding it remains "income from other sources" under Section 244A, not business income, as it compensates for revenue's delay in refunding excess tax. Case-Laws Income Tax Fri, 16 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771133