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    <title>2023 (6) TMI 1539 - ITAT MUMBAI</title>
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    <description>LIBOR was confirmed as the appropriate benchmark for outbound foreign currency loans to associated enterprises, while corporate guarantees to associated enterprises were treated as international transactions and guarantee commission was restricted to 0.35%. Section 14A disallowance could not be made without recorded dissatisfaction with the assessee&#039;s working, and such disallowance could not be added to book profit under section 115JB. Sales tax subsidy and certified emission reduction receipts were treated as capital receipts and excluded from book-profit adjustment. Depreciation on amalgamated assets and consequential depreciation on foreign exchange contract losses were allowed. Additions for alleged bogus purchases, manpower payments and unexplained expenditure were deleted for lack of reliable evidence.</description>
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