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    <title>2026 (7) TMI 1298 - ITAT MUMBAI</title>
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    <description>Transfer-pricing analysis supports LIBOR-based interest benchmarking for loans to associated enterprises and a 0.35% corporate-guarantee commission, while treating guarantees as international transactions. Premature settlement of deferred sales-tax liability is described as capital in nature, and waiver of capital loans for plant and machinery as non-taxable. The notes support deductions for unrecovered business security deposits, overseas subsidiary loan write-offs, and employee stock-option costs subject to verification, but not property advances lacking a revenue-business nexus. They also address restricted disallowance of exempt-income expenditure, exclusion of that disallowance from book profit, electricity-board rates as comparable prices for captive power, and the need for tested third-party evidence before disallowing cargo-handling expenditure.</description>
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      <description>Transfer-pricing analysis supports LIBOR-based interest benchmarking for loans to associated enterprises and a 0.35% corporate-guarantee commission, while treating guarantees as international transactions. Premature settlement of deferred sales-tax liability is described as capital in nature, and waiver of capital loans for plant and machinery as non-taxable. The notes support deductions for unrecovered business security deposits, overseas subsidiary loan write-offs, and employee stock-option costs subject to verification, but not property advances lacking a revenue-business nexus. They also address restricted disallowance of exempt-income expenditure, exclusion of that disallowance from book profit, electricity-board rates as comparable prices for captive power, and the need for tested third-party evidence before disallowing cargo-handling expenditure.</description>
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