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2022 (5) TMI 1406 - AT - Income TaxDisallowance made on account of interest expenses u/s. 14A r.w.s. Rule 8D(2)(ii) and (iii) of the Rules - HELD THAT:- As only exempt income yielding investments have to be taken into consideration whilst computing administrative expenses disallowance u/s 14A r.w.r. 8D(2)(iii). Suffice to say, hon'ble jurisdictional high court's decision in REI Agro Ltd. case [2014 (4) TMI 713 - CALCUTTA HIGH COURT] has already decided the very substantial question of law in assessee's favour. ALP determination for fee for corporate guarantee - HELD THAT:- It is sufficiently clear by now that the assessee’s very arguments have been partly accepted through for benchmarking corporate guarantee transaction is issued @ 0.5% commission. We therefore adopt judicial consistency qua the instant issue as well to decline to Revenue’s corresponding substantive ground in both of its appeals. Adjustment made by TPO for SDTs in respect of transfer of power from eligible unit to other manufacturing units - As gone through the orders of the Co-ordinate bench [2019 (3) TMI 687 - ITAT KOLKATA] in the case of assessee itself which squarely covers the issues involved in the present two appeals before us. Nothing is brought on record to controvert to discussions made and findings given by the Co-ordinate Bench in the case of assessee itself [2017 (2) TMI 685 - ITAT KOLKATA] and that there being no change in the fact pattern and the applicable law, we adopt the judicial consistency from the decisions cited supra, qua the instant issues in the present appeals to uphold the findings given by Ld. CIT(A). Accordingly, we dismiss both the appeals of the revenue.
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