https://www.taxtmi.com/caselaws?id=176093 The ITAT Mumbai held that no disallowance under Section 14A was warranted on dividend income from foreign subsidiaries, as such income is taxable and Section 14A does not apply. Investments made from non-interest-bearing funds were also not subject to disallowance, except for a nominal sum of Rs. 1 lakh allowed for administrative expenses attributable to exempt income. Regarding the ALP adjustment under Section 92CA, the Tribunal found no basis for the TPO's 3% guarantee commission rate, noting the assessee's 0.5% charge to its AE was comparable to the 0.6% paid to an independent bank. Consequently, the Rs. 28,50,353 TP addition was deleted. The appeal was partly allowed, with disallowance under Section 14A limited and the ALP adjustment set aside. en-us Fri, 23 Nov 2012 00:00:00 +0530 Tue, 28 Apr 2026 12:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=176093 The ITAT Mumbai held that no disallowance under Section 14A was warranted on dividend income from foreign subsidiaries, as such income is taxable and Section 14A does not apply. Investments made from non-interest-bearing funds were also not subject to disallowance, except for a nominal sum of Rs. 1 lakh allowed for administrative expenses attributable to exempt income. Regarding the ALP adjustment under Section 92CA, the Tribunal found no basis for the TPO's 3% guarantee commission rate, noting the assessee's 0.5% charge to its AE was comparable to the 0.6% paid to an independent bank. Consequently, the Rs. 28,50,353 TP addition was deleted. The appeal was partly allowed, with disallowance under Section 14A limited and the ALP adjustment set aside. Case-Laws Income Tax Fri, 23 Nov 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=176093