https://www.taxtmi.com/caselaws?id=343422 Disallowance under s.14A read with r.8D was rejected because the taxpayer's own surplus funds substantially exceeded the value of investments, negating any nexus between borrowings and exempt-income investments; consequently, no interest or administrative expense could be estimated for disallowance, and deletion of the disallowance was upheld against the revenue. Disallowance relating to foreign exchange gain was set aside because the foreign currency borrowing was for business expansion and investment on capital account; exchange fluctuation was therefore capital in nature and required adjustment to asset cost rather than recognition on revenue account, and deletion of the disallowance was upheld against the revenue. en-us Thu, 04 May 2017 00:00:00 +0530 Fri, 02 Jan 2026 12:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=343422 Disallowance under s.14A read with r.8D was rejected because the taxpayer's own surplus funds substantially exceeded the value of investments, negating any nexus between borrowings and exempt-income investments; consequently, no interest or administrative expense could be estimated for disallowance, and deletion of the disallowance was upheld against the revenue. Disallowance relating to foreign exchange gain was set aside because the foreign currency borrowing was for business expansion and investment on capital account; exchange fluctuation was therefore capital in nature and required adjustment to asset cost rather than recognition on revenue account, and deletion of the disallowance was upheld against the revenue. Case-Laws Income Tax Thu, 04 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=343422