https://www.taxtmi.com/caselaws?id=242491 For a year before Rule 8D applied, section 14A disallowance for exempt dividend income had to be computed on a reasonable basis, so the assessee's suo motu apportionment of treasury and administrative was accepted and the further disallowance was deleted. For interest on foreign currency loans advanced to a subsidiary, domestic rupee lending rates were held to be an improper benchmark; the correct comparison was with foreign currency borrowing rates and market context, showing the interest charged was at arm's length. No transfer pricing adjustment was warranted. en-us Fri, 10 Jan 2014 00:00:00 +0530 Tue, 14 Jan 2014 14:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=242491 For a year before Rule 8D applied, section 14A disallowance for exempt dividend income had to be computed on a reasonable basis, so the assessee's suo motu apportionment of treasury and administrative was accepted and the further disallowance was deleted. For interest on foreign currency loans advanced to a subsidiary, domestic rupee lending rates were held to be an improper benchmark; the correct comparison was with foreign currency borrowing rates and market context, showing the interest charged was at arm's length. No transfer pricing adjustment was warranted. Case-Laws Income Tax Fri, 10 Jan 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=242491