https://www.taxtmi.com/caselaws?id=463287 ITAT, Cochin (AT) upheld the Revenue's TP adjustments in principle but modified the corporate guarantee fee to 2.45% p.a. (gross), allowing partial relief; the assessed shortfall in ALP as found by DRP remains. The benchmarked interest on excess trade credit at six-month LIBOR + 450 bps (including 100 bps currency risk) was confirmed. The weighted deduction claim under s.35(2AB) was remitted to the AO for fresh adjudication on merits after opportunity to the assessee. The s.14A disallowance was upheld under substituted Rule 8D. en-us Tue, 05 Dec 2023 00:00:00 +0530 Fri, 22 Aug 2025 08:36:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463287 ITAT, Cochin (AT) upheld the Revenue's TP adjustments in principle but modified the corporate guarantee fee to 2.45% p.a. (gross), allowing partial relief; the assessed shortfall in ALP as found by DRP remains. The benchmarked interest on excess trade credit at six-month LIBOR + 450 bps (including 100 bps currency risk) was confirmed. The weighted deduction claim under s.35(2AB) was remitted to the AO for fresh adjudication on merits after opportunity to the assessee. The s.14A disallowance was upheld under substituted Rule 8D. Case-Laws Income Tax Tue, 05 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463287