ITAT ruled in favor of assessee on disallowance of ATS fees & 14A disallowance. Bank guarantee commission & ESOP cost allowed. TP adjustment clarified.

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....The Appellate Tribunal addressed several issues. Firstly, it upheld the deletion of disallowance of Annual Technical Service fees, citing consistency with past decisions. Secondly, it ruled against the disallowance u/s 14A, emphasizing the need for the AO to justify invoking Rule 8D. Thirdly, it rejected the addition of Bank guarantee commission, following past favorable decisions. Fourthly, it disagreed with adding interest on NPA, aligning with previous rulings. Fifthly, it remanded the ESOP cost issue for fresh consideration based on legal precedents. Lastly, it adjusted the TP for international transactions, rejecting equating LOC with bank guarantees and directing ALP adjustment based on safe harbor rules.....