https://www.taxtmi.com/caselaws?id=463371 ITAT upheld the CIT(A)'s restriction of the corporate guarantee commission to 0.5% (reducing the TPO's 2.25% adjustment), declining to interfere as the order aligned with a coordinate bench decision for the relevant AY. On section 14A disallowance, the Tribunal held that while the assessee made a suo motu disallowance under s.14A read with Rule 8D for normal income, such computation cannot be transposed into the book profit computation under Explanation 1(f) to s.115JB(2); reliance on precedents led to excluding Rule 8D-based adjustment from book profits. en-us Thu, 29 Aug 2019 00:00:00 +0530 Thu, 28 Aug 2025 20:47:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463371 ITAT upheld the CIT(A)'s restriction of the corporate guarantee commission to 0.5% (reducing the TPO's 2.25% adjustment), declining to interfere as the order aligned with a coordinate bench decision for the relevant AY. On section 14A disallowance, the Tribunal held that while the assessee made a suo motu disallowance under s.14A read with Rule 8D for normal income, such computation cannot be transposed into the book profit computation under Explanation 1(f) to s.115JB(2); reliance on precedents led to excluding Rule 8D-based adjustment from book profits. Case-Laws Income Tax Thu, 29 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463371