https://www.taxtmi.com/caselaws?id=259768 Section 14A disallowance of interest expenditure was not sustainable where no fresh borrowed investment was shown and the assessee had sufficient own funds; administrative expense disallowance was directed to be recomputed after excluding investments in foreign subsidiaries from the Rule 8D average investment base. For transfer pricing, corporate guarantee commission was benchmarked at 0.5% based on the assessee's internal comparable, reducing the adjustment. Interest on foreign currency loans to associated enterprises was also benchmarked on a LIBOR-plus basis; the China loan was treated as arm's length, while the Dubai loans required limited recomputation using aggregated entity-wise loans and the stated margin. en-us Fri, 27 Feb 2015 00:00:00 +0530 Wed, 20 May 2015 22:51:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259768 Section 14A disallowance of interest expenditure was not sustainable where no fresh borrowed investment was shown and the assessee had sufficient own funds; administrative expense disallowance was directed to be recomputed after excluding investments in foreign subsidiaries from the Rule 8D average investment base. For transfer pricing, corporate guarantee commission was benchmarked at 0.5% based on the assessee's internal comparable, reducing the adjustment. Interest on foreign currency loans to associated enterprises was also benchmarked on a LIBOR-plus basis; the China loan was treated as arm's length, while the Dubai loans required limited recomputation using aggregated entity-wise loans and the stated margin. Case-Laws Income Tax Fri, 27 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259768