Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
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Disallowance under section 14A was confined to the exempt income actually earned, because the Tribunal followed the binding Delhi High Court view that such disallowance cannot exceed the exempt income. The assessee had earned exempt income, while the Assessing Officer computed a higher amount under Rule 8D; the Tribunal restricted the disallowance to the exempt income amount. It also held that the Explanation inserted in section 14A by the Finance Act, 2022 operates prospectively and did not apply to Assessment Year 2017-18. The appeal was partly allowed and the disallowance was restricted accordingly.
Disallowance under section 14A was confined to the exempt income actually earned, because the Tribunal followed the binding Delhi High Court view that such disallowance cannot exceed the exempt income. The assessee had earned exempt income, while the Assessing Officer computed a higher amount under Rule 8D; the Tribunal restricted the disallowance to the exempt income amount. It also held that the Explanation inserted in section 14A by the Finance Act, 2022 operates prospectively and did not apply to Assessment Year 2017-18. The appeal was partly allowed and the disallowance was restricted accordingly.
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