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    <title>Recompute transfer-pricing interest at LIBOR+0.65%, delete TPO interest adjustment; s.14A/Rule8D disallowance unsustainable; major overhaul depreciable at 15%</title>
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    <description>The ITAT remitted and disposed issues as follows: directed recomputation of transfer-pricing interest on outstanding receivables at LIBOR + 0.65% (rejecting application of the Coordinate Bench&#039;s prior basis point and the CIT(A)&#039;s LIBOR + 0.5%); deleted the TPO adjustment relating to interest on share-application monies where shares were allotted within six months; held that no disallowance under s.14A read with Rule 8D is sustainable because the assessee earned no exempt income and the 2022 amendment is prospective; and held that major overhauling expenditure capitalised on plant and machinery qualifies for depreciation at 15%, rejecting the CIT(A)&#039;s contrary deletion.</description>
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    <pubDate>Sat, 13 Sep 2025 08:47:17 +0530</pubDate>
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      <title>Recompute transfer-pricing interest at LIBOR+0.65%, delete TPO interest adjustment; s.14A/Rule8D disallowance unsustainable; major overhaul depreciable at 15%</title>
      <link>https://www.taxtmi.com/highlights?id=92498</link>
      <description>The ITAT remitted and disposed issues as follows: directed recomputation of transfer-pricing interest on outstanding receivables at LIBOR + 0.65% (rejecting application of the Coordinate Bench&#039;s prior basis point and the CIT(A)&#039;s LIBOR + 0.5%); deleted the TPO adjustment relating to interest on share-application monies where shares were allotted within six months; held that no disallowance under s.14A read with Rule 8D is sustainable because the assessee earned no exempt income and the 2022 amendment is prospective; and held that major overhauling expenditure capitalised on plant and machinery qualifies for depreciation at 15%, rejecting the CIT(A)&#039;s contrary deletion.</description>
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      <pubDate>Sat, 13 Sep 2025 08:47:17 +0530</pubDate>
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