https://www.taxtmi.com/caselaws?id=467523 Transfer pricing and allied deduction issues were addressed across multiple assessment years: corporate guarantee commission was aligned at 1% on CUP-based reasoning, with verification of any actual recovery from the subsidiary; notional interest on delayed trade receivables was remitted for fresh examination; and interest on loans to subsidiaries was refixed for one year and remitted for another after considering bank sanction terms and borrowing rates. Section 14A read with Rule 8D disallowance was deleted because own funds exceeded investments and no expenditure was shown for exempt income. Guarantee commission paid for personal guarantees was allowed subject to verification of taxability in the directors' hands, obsolete inventory write-off was allowed, prior-period purchases were sustained, and a blanket expense disallowance for missing PAN/TDS particulars was remitted for verification. en-us Thu, 13 Mar 2025 00:00:00 +0530 Fri, 20 Mar 2026 17:38:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467523 Transfer pricing and allied deduction issues were addressed across multiple assessment years: corporate guarantee commission was aligned at 1% on CUP-based reasoning, with verification of any actual recovery from the subsidiary; notional interest on delayed trade receivables was remitted for fresh examination; and interest on loans to subsidiaries was refixed for one year and remitted for another after considering bank sanction terms and borrowing rates. Section 14A read with Rule 8D disallowance was deleted because own funds exceeded investments and no expenditure was shown for exempt income. Guarantee commission paid for personal guarantees was allowed subject to verification of taxability in the directors' hands, obsolete inventory write-off was allowed, prior-period purchases were sustained, and a blanket expense disallowance for missing PAN/TDS particulars was remitted for verification. Case-Laws Income Tax Thu, 13 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467523