https://www.taxtmi.com/caselaws?id=239345 Fee remitted to Master Card International was held disallowable under section 40(a)(i) because it was paid outside India without TDS and no evidence showed that the payee had discharged tax on the relevant payment. Disallowance under section 14A had to be made on a reasonable basis by identifying expenditure relatable to exempt income, so the matter was remitted for fresh computation and verification. Profits of foreign branches were excluded from total income, following earlier Tribunal orders in the assessee's own case. The Revenue's challenge thus failed, while the assessee obtained relief on foreign-branch profits and a partial remand on section 14A. en-us Wed, 08 May 2013 00:00:00 +0530 Tue, 12 Nov 2013 06:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239345 Fee remitted to Master Card International was held disallowable under section 40(a)(i) because it was paid outside India without TDS and no evidence showed that the payee had discharged tax on the relevant payment. Disallowance under section 14A had to be made on a reasonable basis by identifying expenditure relatable to exempt income, so the matter was remitted for fresh computation and verification. Profits of foreign branches were excluded from total income, following earlier Tribunal orders in the assessee's own case. The Revenue's challenge thus failed, while the assessee obtained relief on foreign-branch profits and a partial remand on section 14A. Case-Laws Income Tax Wed, 08 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239345