TPO Cannot Assess Necessity or Benefits of Expenses on ECB Interest, Guarantee, and Service Fees for Business Purposes.

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Full Text of the Document

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....Addition in respect of interest paid on External Commercial Borrowings (ECB), payment of guarantee fee and service fee - the assessee has been able to substantiate that the payments have been made for the purpose of assessee’s business. The TPO cannot sit in the judgment whether these expenses were necessary for conducting the business or whether any benefit has been derived from the expenditure so incurred. - AT....