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    <title>Short-term loans diverted to capital projects and export pricing for sugar/ferrous goods: limited interest capitalization, CUP upheld under 92C(2)</title>
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    <description>Disallowance of interest was contested on the ground that short-term borrowings were used for long-term investment and only a limited period of capitalization was warranted. Relying on the audit report evidencing diversion of short-term loans to capital projects already put to use, and noting that capital work-in-progress was undisputed, the appellate authority correctly sustained capitalization of interest only for four months and deleted the balance disallowance; the revenue&#039;s challenge was rejected. On transfer pricing for sugar exports, CUP-based benchmarking using FOB-converted prices with an average of NYBOT and Kingsman rates, along with the statutory tolerance range under section 92C(2), was upheld; no interference was warranted. On ferrous exports, contracts were accepted as CUP and adjustment restricted; the revenue&#039;s ground failed. - ITAT</description>
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    <pubDate>Thu, 01 Jan 2026 08:17:53 +0530</pubDate>
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      <title>Short-term loans diverted to capital projects and export pricing for sugar/ferrous goods: limited interest capitalization, CUP upheld under 92C(2)</title>
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      <description>Disallowance of interest was contested on the ground that short-term borrowings were used for long-term investment and only a limited period of capitalization was warranted. Relying on the audit report evidencing diversion of short-term loans to capital projects already put to use, and noting that capital work-in-progress was undisputed, the appellate authority correctly sustained capitalization of interest only for four months and deleted the balance disallowance; the revenue&#039;s challenge was rejected. On transfer pricing for sugar exports, CUP-based benchmarking using FOB-converted prices with an average of NYBOT and Kingsman rates, along with the statutory tolerance range under section 92C(2), was upheld; no interference was warranted. On ferrous exports, contracts were accepted as CUP and adjustment restricted; the revenue&#039;s ground failed. - ITAT</description>
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