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    <title>2024 (7) TMI 1697 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai partially allowed the appeal. The section 14A disallowance was restricted to the assessee&#039;s suo-moto computation (Rs.1,17,42,084) and the corresponding adjustment to book profits under section 115JB deleted. Deductions under section 80IA were upheld without allocation of head-office expenses or denial for CENVAT credit; corporate advertisement and lease equalization charges were allowed as revenue expenditure. Interest on unpaid electricity tax was treated as compensatory (section 43B not applicable). Transfer-pricing addition for guarantee fees was sustained at the CIT(A)&#039;s restricted ALP; several recurring additions (section 40(a)(ia), CENVAT in stock, leave provisions) were deleted. Treatment of certain incentives was remitted to AO for fresh factual examination.</description>
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    <pubDate>Mon, 01 Jul 2024 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=463979</link>
      <description>ITAT Mumbai partially allowed the appeal. The section 14A disallowance was restricted to the assessee&#039;s suo-moto computation (Rs.1,17,42,084) and the corresponding adjustment to book profits under section 115JB deleted. Deductions under section 80IA were upheld without allocation of head-office expenses or denial for CENVAT credit; corporate advertisement and lease equalization charges were allowed as revenue expenditure. Interest on unpaid electricity tax was treated as compensatory (section 43B not applicable). Transfer-pricing addition for guarantee fees was sustained at the CIT(A)&#039;s restricted ALP; several recurring additions (section 40(a)(ia), CENVAT in stock, leave provisions) were deleted. Treatment of certain incentives was remitted to AO for fresh factual examination.</description>
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