https://www.taxtmi.com/caselaws?id=236906 The ITAT Mumbai held that disallowance under section 14A is justified even if no exempt income is realized, aligning with precedent. Rental income from subletting was held not taxable under Income from House Property as the assessee was neither owner nor deemed owner; it was to be taxed under Income from Other Sources with eligible deductions allowed, avoiding double claims. Regarding transfer pricing, reimbursement of expenses between associated enterprises qualifies as an international transaction under sections 92B and 92F(v). The Tribunal excluded certain comparables involving related party transactions and remanded the matter for fresh determination by AO/TPO, emphasizing similarity in the nature of services rendered as the key criterion for comparables. The decision was ultimately in favor of the assessee. en-us Fri, 11 Jan 2013 00:00:00 +0530 Tue, 05 Aug 2025 11:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236906 The ITAT Mumbai held that disallowance under section 14A is justified even if no exempt income is realized, aligning with precedent. Rental income from subletting was held not taxable under Income from House Property as the assessee was neither owner nor deemed owner; it was to be taxed under Income from Other Sources with eligible deductions allowed, avoiding double claims. Regarding transfer pricing, reimbursement of expenses between associated enterprises qualifies as an international transaction under sections 92B and 92F(v). The Tribunal excluded certain comparables involving related party transactions and remanded the matter for fresh determination by AO/TPO, emphasizing similarity in the nature of services rendered as the key criterion for comparables. The decision was ultimately in favor of the assessee. Case-Laws Income Tax Fri, 11 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236906