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2014 (2) TMI 1421 - AT - Income TaxExcess deduction u/s 80IB/80IC - method of allocation consistently adopted by the Appellant and in re-allocating 50% of the following overheads of the non-eligible undertakings to the eligible undertakings of the Appellant, while computing the deduction u/s 80IB/80IC - HELD THAT:- As decided in assessee own case for AY 2006-07 [2014 (4) TMI 520 - ITAT MUMBAI] allocation of expenses made by the assessee between eligible business and non-eligible business for the purpose of computing deduction u/s 80IB/80IC of the Act was reasonable and there was no justifiable reason for the A.O. to disturb the same and make re-allocation on adhoc basis. We, therefore, delete the addition made by the A.O. by restricting the claim of the assessee for deduction u/s 80IB/80IC by reallocating the common indirect expenses and allow ground No. 1 & 2 of the assessee’s appeal. TP Adjustment - treating the guarantee to a banker as an ‘international transaction’ within the meaning of Section 92B - HELD THAT:- The issue covered in the grounds are covered by the decision of the Coordinate Bench in its own case in [2014 (4) TMI 520 - ITAT MUMBAI] wherein take the rate of guarantee commission at 0.5% as ALP by respectfully following the decision of coordinate Bench of this Tribunal in the case of Nimbus Communications Ltd. [2013 (9) TMI 204 - ITAT MUMBAI]
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