https://www.taxtmi.com/caselaws?id=777318 ITAT, Mumbai upheld disallowance of occupancy/depreciation recharge under sections 32/37, finding the assessee neither owned nor incurred the leasehold asset cost. The tribunal deleted the addition relating to RSU/ESOP expenditure. An intimation discrepancy under section 143(1) was directed to be decided by the AO via the pending section 154 rectification. CCDs were held to be debt until conversion; interest is allowable but transfer-pricing benchmarking of the interest was restored to the TPO/AO for de novo ALP determination. TDS credit and applicability of interest under sections 234A/234B were remitted to the jurisdictional AO for verification and action. en-us Fri, 22 Aug 2025 00:00:00 +0530 Mon, 25 Aug 2025 12:49:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777318 ITAT, Mumbai upheld disallowance of occupancy/depreciation recharge under sections 32/37, finding the assessee neither owned nor incurred the leasehold asset cost. The tribunal deleted the addition relating to RSU/ESOP expenditure. An intimation discrepancy under section 143(1) was directed to be decided by the AO via the pending section 154 rectification. CCDs were held to be debt until conversion; interest is allowable but transfer-pricing benchmarking of the interest was restored to the TPO/AO for de novo ALP determination. TDS credit and applicability of interest under sections 234A/234B were remitted to the jurisdictional AO for verification and action. Case-Laws Income Tax Fri, 22 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777318