https://www.taxtmi.com/caselaws?id=243675 Non-deduction of tax at source on payment to MasterCard led to sustained disallowance under section 40(a)(i) because the record did not show that the recipient had paid tax so as to permit allowance in the relevant year. The section 14A disallowance was not accepted on a flat percentage basis; it required a reasonable computation of expenditure attributable to exempt income, so the matter was remitted for fresh determination. Profits of foreign branches were not added to the resident assessee's total income in light of the settled position in its own case, and the additional ground on section 115JA was rejected as not arising from the impugned order. en-us Wed, 08 May 2013 00:00:00 +0530 Fri, 07 Feb 2014 19:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=243675 Non-deduction of tax at source on payment to MasterCard led to sustained disallowance under section 40(a)(i) because the record did not show that the recipient had paid tax so as to permit allowance in the relevant year. The section 14A disallowance was not accepted on a flat percentage basis; it required a reasonable computation of expenditure attributable to exempt income, so the matter was remitted for fresh determination. Profits of foreign branches were not added to the resident assessee's total income in light of the settled position in its own case, and the additional ground on section 115JA was rejected as not arising from the impugned order. Case-Laws Income Tax Wed, 08 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=243675