Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Allowable deduction of interest paid on the borrowings - Section 14A and Section 36(1)(iii) - Exempted dividend income - Based on the discussions and findings, the court dismissed the appeal, affirming the decision of the ITAT. It upheld the disallowance of the interest expense, considering the provisions of Section 14A and the principles established in the Maxopp Investment Ltd. case. The expenditure incurred on interest paid on borrowed funds for investment in shares of the two companies, from which dividend income does not form part of the total income, was held to be hit by Section 14A of the Act and not allowable as deduction.
Allowable deduction of interest paid on the borrowings - Section 14A and Section 36(1)(iii) - Exempted dividend income - Based on the discussions and findings, the court dismissed the appeal, affirming the decision of the ITAT. It upheld the disallowance of the interest expense, considering the provisions of Section 14A and the principles established in the Maxopp Investment Ltd. case. The expenditure incurred on interest paid on borrowed funds for investment in shares of the two companies, from which dividend income does not form part of the total income, was held to be hit by Section 14A of the Act and not allowable as deduction.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
