https://www.taxtmi.com/caselaws?id=352716 The commentary examines the scope of section 144C and the meaning of an "eligible assessee," noting that a draft assessment was challenged on the basis that no transfer pricing adjustment had been proposed and that limitation was also disputed. It also discusses whether a remand confined to section 14A required a fresh reference to the Transfer Pricing Officer, and states that a limitation plea may not succeed where the assessment is made to give effect to that remand. On the merits, it explains that proportionate disallowance under section 14A is justified where the assessee fails to show that exempt-income investments were made entirely from interest-free funds or that no expenditure was attributable to exempt income. en-us Mon, 03 Jul 2017 00:00:00 +0530 Wed, 20 Dec 2017 08:45:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=352716 The commentary examines the scope of section 144C and the meaning of an "eligible assessee," noting that a draft assessment was challenged on the basis that no transfer pricing adjustment had been proposed and that limitation was also disputed. It also discusses whether a remand confined to section 14A required a fresh reference to the Transfer Pricing Officer, and states that a limitation plea may not succeed where the assessment is made to give effect to that remand. On the merits, it explains that proportionate disallowance under section 14A is justified where the assessee fails to show that exempt-income investments were made entirely from interest-free funds or that no expenditure was attributable to exempt income. Case-Laws Income Tax Mon, 03 Jul 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=352716