https://www.taxtmi.com/caselaws?id=463606 ITAT upheld that corporate guarantees to foreign AE are international transactions; ALP for guarantee commission fixed at 0.5% (partial allowance of TP ground). Sec.14A disallowance under Rule 8D deleted as no exempt income. DSIR Form 3CL approval is binding under Sec.35(2AB)/Rule 6(7A); weighted deduction at 150% allowed on approved R&D expenditure (Rs.529.78 crore ? deduction Rs.794.67 crore) and remaining approved capital expenditure allowed; no excess claim disallowed. Deduction under s.80IC for the eligible unit at Pantnagar allowed based on audited stand-alone accounts; s.80G deduction also sustained. en-us Mon, 07 Jul 2025 00:00:00 +0530 Mon, 08 Sep 2025 18:59:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463606 ITAT upheld that corporate guarantees to foreign AE are international transactions; ALP for guarantee commission fixed at 0.5% (partial allowance of TP ground). Sec.14A disallowance under Rule 8D deleted as no exempt income. DSIR Form 3CL approval is binding under Sec.35(2AB)/Rule 6(7A); weighted deduction at 150% allowed on approved R&D expenditure (Rs.529.78 crore ? deduction Rs.794.67 crore) and remaining approved capital expenditure allowed; no excess claim disallowed. Deduction under s.80IC for the eligible unit at Pantnagar allowed based on audited stand-alone accounts; s.80G deduction also sustained. Case-Laws Income Tax Mon, 07 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463606