https://www.taxtmi.com/caselaws?id=284150 Section 14A disallowance requires factual examination of the nexus between borrowed funds, investments and exempt income, particularly where investments are strategic holdings; it is not to be mechanically added to book profit under section 115JB. Non-exclusive, turnover-linked royalty for use of a logo, without ownership or transfer rights, is treated as revenue expenditure. Statutory transfers to reserve funds are application of income rather than diversion by overriding title and are not excluded from book profit. Interest on excess refunds is not a business deduction. Disallowance for non-deduction of tax at source and bad-debt deductions depend on factual verification of the statutory conditions. en-us Mon, 01 May 2017 00:00:00 +0530 Mon, 04 Nov 2019 06:31:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=284150 Section 14A disallowance requires factual examination of the nexus between borrowed funds, investments and exempt income, particularly where investments are strategic holdings; it is not to be mechanically added to book profit under section 115JB. Non-exclusive, turnover-linked royalty for use of a logo, without ownership or transfer rights, is treated as revenue expenditure. Statutory transfers to reserve funds are application of income rather than diversion by overriding title and are not excluded from book profit. Interest on excess refunds is not a business deduction. Disallowance for non-deduction of tax at source and bad-debt deductions depend on factual verification of the statutory conditions. Case-Laws Income Tax Mon, 01 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=284150