https://www.taxtmi.com/caselaws?id=394743 Sufficient own funds and surplus can defeat an interest disallowance under section 14A read with rule 8D(2)(ii) where borrowed funds were not used for investments, so the interest component was deleted. For rule 8D(2)(iii), the computation of average investments must be confined to investments that actually yielded exempt income during the relevant year, requiring recomputation on that basis. A disallowance under section 40(a)(ia) concerning payments to foreign consultants was remanded for fresh examination because supporting agreements and evidence were not before the lower authorities. Interest paid to HSBC (Mauritius) Ltd fell within the applicable DTAA exemption for a qualifying bank, so the related disallowance was deleted. en-us Wed, 12 Feb 2020 00:00:00 +0530 Thu, 23 Apr 2020 11:02:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=394743 Sufficient own funds and surplus can defeat an interest disallowance under section 14A read with rule 8D(2)(ii) where borrowed funds were not used for investments, so the interest component was deleted. For rule 8D(2)(iii), the computation of average investments must be confined to investments that actually yielded exempt income during the relevant year, requiring recomputation on that basis. A disallowance under section 40(a)(ia) concerning payments to foreign consultants was remanded for fresh examination because supporting agreements and evidence were not before the lower authorities. Interest paid to HSBC (Mauritius) Ltd fell within the applicable DTAA exemption for a qualifying bank, so the related disallowance was deleted. Case-Laws Income Tax Wed, 12 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=394743