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2023 (6) TMI 1063 - ITAT MUMBAITP adjustment towards payment of central services - inter group services - HELD THAT:- The assessee has submitted evidences not only demonstrating the rendition of central services but also commensurate benefits derived from such services to the assessee. The assessee has done the bench marking analysis similar to AY 2015-16 and 2016-17 for the year under consideration also and therefore the impugned issue is squarely covered by the above decision of the coordinate bench and therefore respectfully following the same we direct the AO/TPO to delete the addition made towards inter group services. Disallowance u/s 14A r.w.r. 8D - AR submitted that the assessee’s suo-moto disallowance is appropriate and scientific - HELD THAT:- For the year under consideration assessee has investments the details of which has already been furnished before the AO. As noticed that that AO has applied Rule 8D without having recorded his satisfaction or examining the nature of investments whether they have yielded any exempt income or not. Therefore respectfully following the above decision of the coordinate bench in assessee's own case we delete the disallowance made by the assessing officer. Disallowance of ESOP expenditure - ESOP expenses has not crystalised and that the same is capital in nature - HELD THAT:- As decided in assessee own case [2023 (3) TMI 1376 - ITAT MUMBAI] we hold that the addition made by the AO towards ESOP expenses be deleted.
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