https://www.taxtmi.com/caselaws?id=469606 Corporate guarantee transfer pricing cannot be benchmarked by treating it as a bank guarantee; the matter was remanded for fresh benchmarking. Interest on loans to an associated enterprise was benchmarked on contractual terms and comparable uncontrolled price data, and the adjustment was deleted. Deduction under section 80IA was allowed for profits from rail systems and water supply systems as eligible infrastructure facilities. Receipts from sale of CERs were treated as capital receipts and held not taxable. Section 14A disallowance under Rule 8D was partly deleted because own funds exceeded investments and the investment base had to be restricted to exempt-yielding investments; the corresponding MAT adjustment under section 115JB was also deleted. Write-back of project creditors tied to capital borrowing was not taxable under section 41(1). en-us Thu, 04 May 2023 00:00:00 +0530 Wed, 24 Jun 2026 11:01:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469606 Corporate guarantee transfer pricing cannot be benchmarked by treating it as a bank guarantee; the matter was remanded for fresh benchmarking. Interest on loans to an associated enterprise was benchmarked on contractual terms and comparable uncontrolled price data, and the adjustment was deleted. Deduction under section 80IA was allowed for profits from rail systems and water supply systems as eligible infrastructure facilities. Receipts from sale of CERs were treated as capital receipts and held not taxable. Section 14A disallowance under Rule 8D was partly deleted because own funds exceeded investments and the investment base had to be restricted to exempt-yielding investments; the corresponding MAT adjustment under section 115JB was also deleted. Write-back of project creditors tied to capital borrowing was not taxable under section 41(1). Case-Laws Income Tax Thu, 04 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469606