https://www.taxtmi.com/caselaws?id=399769 The tribunal partly allowed the appeal, emphasizing that disallowances under section 14A should be limited to the extent of exempt income earned by the assessee. It ruled that satisfaction under section 14A(2) is necessary only if there are suo-moto disallowances by the assessee. The tribunal dismissed other grounds as not pressed by the assessee, including the applicability of transfer pricing provisions and adjustments made by the TPO on interest transactions between the Indian branch and its head office. The judgment provided detailed reasoning based on legal principles and precedents, addressing each issue comprehensively. en-us Wed, 05 Aug 2020 00:00:00 +0530 Tue, 05 Nov 2024 12:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=399769 The tribunal partly allowed the appeal, emphasizing that disallowances under section 14A should be limited to the extent of exempt income earned by the assessee. It ruled that satisfaction under section 14A(2) is necessary only if there are suo-moto disallowances by the assessee. The tribunal dismissed other grounds as not pressed by the assessee, including the applicability of transfer pricing provisions and adjustments made by the TPO on interest transactions between the Indian branch and its head office. The judgment provided detailed reasoning based on legal principles and precedents, addressing each issue comprehensively. Case-Laws Income Tax Wed, 05 Aug 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=399769