https://www.taxtmi.com/caselaws?id=192068 Transaction charges, VSAT and leaseline payments to a stock exchange were treated as not constituting fees for technical services, so tax deduction at source was not attracted and the related disallowance could not stand. Separate books, separate demat accounts, the assessee's investment intent, and CBDT guidance on dual portfolios supported classification of short-term share gains as capital gains rather than business income. Rule 8D was held inapplicable to assessment year 2005-06 because it is not retrospective, so the section 14A disallowance could not be recomputed mechanically and required fresh examination of expenditure attributable to exempt income. en-us Fri, 03 Dec 2010 00:00:00 +0530 Thu, 11 May 2017 17:19:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=192068 Transaction charges, VSAT and leaseline payments to a stock exchange were treated as not constituting fees for technical services, so tax deduction at source was not attracted and the related disallowance could not stand. Separate books, separate demat accounts, the assessee's investment intent, and CBDT guidance on dual portfolios supported classification of short-term share gains as capital gains rather than business income. Rule 8D was held inapplicable to assessment year 2005-06 because it is not retrospective, so the section 14A disallowance could not be recomputed mechanically and required fresh examination of expenditure attributable to exempt income. Case-Laws Income Tax Fri, 03 Dec 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=192068