https://www.taxtmi.com/caselaws?id=784256 Disallowance of interest was challenged on the ground that short-term borrowings were allegedly used for fixed assets. Relying on the audit report showing diversion of short-term loans to long-term investment and noting that the projects were put to use in July 2004 with interest capitalised for only four months, and that capital work-in-progress was undisputed, the ITAT upheld the CIT(A)'s application of the interest rate for four months on the relevant funds; the Revenue's ground was rejected. On TP for sugar exports, the ITAT affirmed conversion of CIF to FOB and the CIT(A)'s direction to compute ALP using the average of NYBOT and Kingsman prices (with the ±5% proviso to s.92C(2)); the Revenue's ground failed. On TP for ferrous exports, the ITAT upheld rejection of IBIS quotes and adoption of two comparable contracts as CUP, sustaining restricted adjustment without ±5% benefit; the Revenue's ground was rejected. en-us Tue, 30 Dec 2025 00:00:00 +0530 Thu, 01 Jan 2026 08:17:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784256 Disallowance of interest was challenged on the ground that short-term borrowings were allegedly used for fixed assets. Relying on the audit report showing diversion of short-term loans to long-term investment and noting that the projects were put to use in July 2004 with interest capitalised for only four months, and that capital work-in-progress was undisputed, the ITAT upheld the CIT(A)'s application of the interest rate for four months on the relevant funds; the Revenue's ground was rejected. On TP for sugar exports, the ITAT affirmed conversion of CIF to FOB and the CIT(A)'s direction to compute ALP using the average of NYBOT and Kingsman prices (with the ±5% proviso to s.92C(2)); the Revenue's ground failed. On TP for ferrous exports, the ITAT upheld rejection of IBIS quotes and adoption of two comparable contracts as CUP, sustaining restricted adjustment without ±5% benefit; the Revenue's ground was rejected. Case-Laws Income Tax Tue, 30 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784256