https://www.taxtmi.com/caselaws?id=236759 For years prior to Rule 8D, section 14A requires only a reasonable, fact-based disallowance for exempt income. Power charges and research and development allocations to section 10B units may need fresh factual verification before apportionment is sustained. Additional depreciation is available where new plant and machinery is acquired and installed for manufacturing use, while losses of section 10B units can be set off against profits of non-section 10B units. Payments for clearing, warehousing, freight and allied services rendered outside India are not automatically fees for technical or managerial services, so section 195 withholding and section 40(a)(i) disallowance do not arise on the stated facts. Unutilised additional depreciation is not carry forwardable, and UPS may qualify for higher depreciation as an energy-saving device. en-us Fri, 22 Mar 2013 00:00:00 +0530 Sat, 07 Sep 2013 12:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236759 For years prior to Rule 8D, section 14A requires only a reasonable, fact-based disallowance for exempt income. Power charges and research and development allocations to section 10B units may need fresh factual verification before apportionment is sustained. Additional depreciation is available where new plant and machinery is acquired and installed for manufacturing use, while losses of section 10B units can be set off against profits of non-section 10B units. Payments for clearing, warehousing, freight and allied services rendered outside India are not automatically fees for technical or managerial services, so section 195 withholding and section 40(a)(i) disallowance do not arise on the stated facts. Unutilised additional depreciation is not carry forwardable, and UPS may qualify for higher depreciation as an energy-saving device. Case-Laws Income Tax Fri, 22 Mar 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236759