https://www.taxtmi.com/caselaws?id=468541 Transfer pricing adjustments for corporate guarantee commission, notional interest on delayed trade receivables, and alleged shortfall in interest on a subsidiary loan were not finally upheld; the Tribunal remitted them for reconsideration, noting comparables, business practice on receivables, and foreign-currency borrowing terms. The proposed mark-to-market addition on forward contracts was also set aside for de novo verification because the tax computation treatment under Ind AS and ICDS had not been properly examined. An alternate deduction claim for expenditure earlier denied under weighted deduction for in-house research and development was permitted to be raised and remitted for fresh adjudication. The section 14A disallowance was likewise sent back for factual verification on own funds, investment base, exclusion of foreign subsidiaries, and possible duplication. en-us Wed, 11 Dec 2024 00:00:00 +0530 Tue, 12 May 2026 16:15:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468541 Transfer pricing adjustments for corporate guarantee commission, notional interest on delayed trade receivables, and alleged shortfall in interest on a subsidiary loan were not finally upheld; the Tribunal remitted them for reconsideration, noting comparables, business practice on receivables, and foreign-currency borrowing terms. The proposed mark-to-market addition on forward contracts was also set aside for de novo verification because the tax computation treatment under Ind AS and ICDS had not been properly examined. An alternate deduction claim for expenditure earlier denied under weighted deduction for in-house research and development was permitted to be raised and remitted for fresh adjudication. The section 14A disallowance was likewise sent back for factual verification on own funds, investment base, exclusion of foreign subsidiaries, and possible duplication. Case-Laws Income Tax Wed, 11 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468541