https://www.taxtmi.com/caselaws?id=252691 Transaction charges paid to the stock exchange were treated as fees for technical services, attracting tax deduction under section 194J and disallowance under section 40(a)(ia) when tax was not deducted. V-SAT charges were held not to constitute technical services, so section 194J and the corresponding disallowance under section 40(a)(ia) did not apply to that component. For assessment year 2007-08, Rule 8D was held inapplicable for section 14A computation, but exempt-income expenditure still required a reasonable apportionment on facts. The result was a mixed outcome: the transaction-charge disallowance was sustained, the V-SAT disallowance was deleted, and the section 14A issue was confined to reasonable estimation. en-us Fri, 22 Aug 2014 00:00:00 +0530 Sat, 01 Nov 2014 07:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252691 Transaction charges paid to the stock exchange were treated as fees for technical services, attracting tax deduction under section 194J and disallowance under section 40(a)(ia) when tax was not deducted. V-SAT charges were held not to constitute technical services, so section 194J and the corresponding disallowance under section 40(a)(ia) did not apply to that component. For assessment year 2007-08, Rule 8D was held inapplicable for section 14A computation, but exempt-income expenditure still required a reasonable apportionment on facts. The result was a mixed outcome: the transaction-charge disallowance was sustained, the V-SAT disallowance was deleted, and the section 14A issue was confined to reasonable estimation. Case-Laws Income Tax Fri, 22 Aug 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252691