https://www.taxtmi.com/caselaws?id=791528 Corporate guarantee fees charged to associated enterprises at 0.25% were treated as arm's length where supported by bank quotations, the selected transfer pricing method and consistent earlier-year treatment; the proposed higher adjustment was deleted. Software cost allocations characterised as pure cost-to-cost recoveries did not warrant a manufacturing-entity mark-up and the adjustment was deleted. Captive power transactions require benchmarking against rates charged by the State Electricity Board to industrial consumers rather than non-comparable exchange or supplier-side averages; the power adjustments were remanded for verification. Deduction under section 80-IA cannot be reduced twice for the same power adjustment. Section 14A disallowance without exempt income was deleted, while book-profit education cess and section 234A interest were remanded for factual verification. en-us Fri, 08 May 2026 00:00:00 +0530 Wed, 13 May 2026 08:36:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791528 Corporate guarantee fees charged to associated enterprises at 0.25% were treated as arm's length where supported by bank quotations, the selected transfer pricing method and consistent earlier-year treatment; the proposed higher adjustment was deleted. Software cost allocations characterised as pure cost-to-cost recoveries did not warrant a manufacturing-entity mark-up and the adjustment was deleted. Captive power transactions require benchmarking against rates charged by the State Electricity Board to industrial consumers rather than non-comparable exchange or supplier-side averages; the power adjustments were remanded for verification. Deduction under section 80-IA cannot be reduced twice for the same power adjustment. Section 14A disallowance without exempt income was deleted, while book-profit education cess and section 234A interest were remanded for factual verification. Case-Laws Income Tax Fri, 08 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791528