https://www.taxtmi.com/caselaws?id=249428 For assessment years before rule 8D became applicable, section 14A disallowance for exempt income had to be made on a reasonable basis, and the adjustment was restricted to 2% of exempt income. Interest paid to the head office or overseas branches was allowed as a deduction where the corresponding interest receipts on Nostro accounts and overseas placements were taxed. In transfer pricing for external commercial borrowings arranged by overseas branches, only fees and other charges, not interest, were attributed for adjustment, at 20%. Loss on revaluation of unmatured forward exchange contracts was allowable, while the foreign company's business income remained taxable at the rate applicable to foreign companies. en-us Wed, 18 Jun 2014 00:00:00 +0530 Mon, 14 Jul 2014 09:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=249428 For assessment years before rule 8D became applicable, section 14A disallowance for exempt income had to be made on a reasonable basis, and the adjustment was restricted to 2% of exempt income. Interest paid to the head office or overseas branches was allowed as a deduction where the corresponding interest receipts on Nostro accounts and overseas placements were taxed. In transfer pricing for external commercial borrowings arranged by overseas branches, only fees and other charges, not interest, were attributed for adjustment, at 20%. Loss on revaluation of unmatured forward exchange contracts was allowable, while the foreign company's business income remained taxable at the rate applicable to foreign companies. Case-Laws Income Tax Wed, 18 Jun 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=249428