https://www.taxtmi.com/caselaws?id=467546 Section 94B cannot be used as an arm's length benchmarking mechanism under Rule 10AB, because it is a disallowance provision confined to interest expenditure claimed as deductible in computing business income. Interest capitalised to work-in-progress and not claimed as a deduction in the relevant year falls outside its scope for that year, so the adjustment was unsustainable. The assessment order also failed because it did not conform to the DRP's binding direction to avoid double disallowance where the assessee had already made a voluntary disallowance. Short grant of TDS credit required record verification and allowance of the correct credit. en-us Thu, 29 May 2025 00:00:00 +0530 Mon, 23 Mar 2026 20:37:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467546 Section 94B cannot be used as an arm's length benchmarking mechanism under Rule 10AB, because it is a disallowance provision confined to interest expenditure claimed as deductible in computing business income. Interest capitalised to work-in-progress and not claimed as a deduction in the relevant year falls outside its scope for that year, so the adjustment was unsustainable. The assessment order also failed because it did not conform to the DRP's binding direction to avoid double disallowance where the assessee had already made a voluntary disallowance. Short grant of TDS credit required record verification and allowance of the correct credit. Case-Laws Income Tax Thu, 29 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467546