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Exempt dividend income earned by assessee. Interest-free owned funds exceeded investments in tax-free securities, disallowance u/r 8D(2)(ii) not warranted. For Rule 8D(2)(iii) disallowance, only investments yielding exempt income to be considered, recomputation directed. No adjustment for section 14A disallowance to book profits u/s 115JB, as not proposed in draft order or directed by DRP. Discount to pre-paid distributors not subject to TDS u/s 194H, no disallowance u/s 40(a)(ia). Depreciation on 3G spectrum allowed u/s 32(1)(ii). Brand royalty payment to AE remanded to TPO/AO for fresh benchmarking. Reimbursement of expenses to AE remanded for substantiation. Additional TDS credit to be granted as per law after verification. Legal terminology from Income Tax Act and Rules used.
Exempt dividend income earned by assessee. Interest-free owned funds exceeded investments in tax-free securities, disallowance u/r 8D(2)(ii) not warranted. For Rule 8D(2)(iii) disallowance, only investments yielding exempt income to be considered, recomputation directed. No adjustment for section 14A disallowance to book profits u/s 115JB, as not proposed in draft order or directed by DRP. Discount to pre-paid distributors not subject to TDS u/s 194H, no disallowance u/s 40(a)(ia). Depreciation on 3G spectrum allowed u/s 32(1)(ii). Brand royalty payment to AE remanded to TPO/AO for fresh benchmarking. Reimbursement of expenses to AE remanded for substantiation. Additional TDS credit to be granted as per law after verification. Legal terminology from Income Tax Act and Rules used.
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