https://www.taxtmi.com/caselaws?id=248736 A non-speaking transfer pricing order that fails to record reasons for rejecting objections, or to give the assessee an effective opportunity to substantiate arm's length price, cannot be sustained; the royalty, import, and technical fee adjustments were set aside and remitted for fresh decision. The disallowance under section 14A read with Rule 8D also required reconsideration because the factual nexus between expenditure and exempt income had to be examined, including the assessee's claim that investments were funded from surplus funds. That disallowance was likewise set aside and restored for fresh adjudication. en-us Fri, 30 May 2014 00:00:00 +0530 Mon, 23 Jun 2014 08:35:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=248736 A non-speaking transfer pricing order that fails to record reasons for rejecting objections, or to give the assessee an effective opportunity to substantiate arm's length price, cannot be sustained; the royalty, import, and technical fee adjustments were set aside and remitted for fresh decision. The disallowance under section 14A read with Rule 8D also required reconsideration because the factual nexus between expenditure and exempt income had to be examined, including the assessee's claim that investments were funded from surplus funds. That disallowance was likewise set aside and restored for fresh adjudication. Case-Laws Income Tax Fri, 30 May 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=248736