https://www.taxtmi.com/highlights?id=88738 ITAT Decision Summary: The ITAT comprehensively allowed multiple tax-related claims for the assessee, including: (a) validating internal CUP benchmarking for interest on advances to associated enterprises, (b) rejecting notional interest adjustments on outstanding receivables, (c) permitting weighted deduction under section 35(2AB) for R&D expenditure, (d) upholding depreciation on goodwill from intra-group amalgamation, (e) deleting disallowances related to common expense allocation, (f) rejecting interest capitalization disallowance under section 36(1)(iii), (g) dismissing section 14A disallowance, and (h) upholding non-deduction of TDS on non-resident commission. The tribunal consistently followed precedential rulings and applied principles of commercial reality, predominantly deciding in favor of the assessee across multiple tax dispute grounds. en-us Mon, 26 May 2025 08:52:05 +0530 Mon, 26 May 2025 08:52:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=88738 ITAT Decision Summary: The ITAT comprehensively allowed multiple tax-related claims for the assessee, including: (a) validating internal CUP benchmarking for interest on advances to associated enterprises, (b) rejecting notional interest adjustments on outstanding receivables, (c) permitting weighted deduction under section 35(2AB) for R&D expenditure, (d) upholding depreciation on goodwill from intra-group amalgamation, (e) deleting disallowances related to common expense allocation, (f) rejecting interest capitalization disallowance under section 36(1)(iii), (g) dismissing section 14A disallowance, and (h) upholding non-deduction of TDS on non-resident commission. The tribunal consistently followed precedential rulings and applied principles of commercial reality, predominantly deciding in favor of the assessee across multiple tax dispute grounds. Highlights Income Tax Mon, 26 May 2025 08:52:05 +0530 https://www.taxtmi.com/highlights?id=88738