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    <title>2025 (9) TMI 1619 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai allowed deletion of TP adjustments imposed on AMP expenses and on royalty/technology payments, and directed deletion of service-fee TP adjustments (including global services) following a co-ordinate bench decision, thereby ruling in favour of the assessee on those grounds. Disallowance under section 14A/read with Rule 8D was remitted to the AO for re-adjudication in light of the assessee&#039;s suo-moto salary disallowance and available own funds. Allocation of expenses between Unit-I and Unit-II was revisited, AO&#039;s basis rejected and related disallowances deleted. Interest under section 234C and MAT credit issues were remitted to the AO for recomputation and appropriate carry-forward credit, respectively.</description>
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    <pubDate>Fri, 22 Aug 2025 00:00:00 +0530</pubDate>
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      <description>ITAT Mumbai allowed deletion of TP adjustments imposed on AMP expenses and on royalty/technology payments, and directed deletion of service-fee TP adjustments (including global services) following a co-ordinate bench decision, thereby ruling in favour of the assessee on those grounds. Disallowance under section 14A/read with Rule 8D was remitted to the AO for re-adjudication in light of the assessee&#039;s suo-moto salary disallowance and available own funds. Allocation of expenses between Unit-I and Unit-II was revisited, AO&#039;s basis rejected and related disallowances deleted. Interest under section 234C and MAT credit issues were remitted to the AO for recomputation and appropriate carry-forward credit, respectively.</description>
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