https://www.taxtmi.com/caselaws?id=406333 Rule 8D could not be applied retrospectively before assessment year 2008-09, and the section 14A disallowance failed on facts because the assessee's own funds and cash profits exceeded the investments yielding exempt income. Closely linked export transactions with the associated enterprise had to be benchmarked on an aggregated basis, not by selecting only adverse instances, and the transfer pricing adjustment was deleted. Additional claims concerning carbon credit receipts, interest subsidy under the Technology Up-gradation Fund scheme, and education cess were admitted but remitted for fresh verification and decision in accordance with law. en-us Tue, 06 Apr 2021 00:00:00 +0530 Mon, 12 Apr 2021 08:15:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406333 Rule 8D could not be applied retrospectively before assessment year 2008-09, and the section 14A disallowance failed on facts because the assessee's own funds and cash profits exceeded the investments yielding exempt income. Closely linked export transactions with the associated enterprise had to be benchmarked on an aggregated basis, not by selecting only adverse instances, and the transfer pricing adjustment was deleted. Additional claims concerning carbon credit receipts, interest subsidy under the Technology Up-gradation Fund scheme, and education cess were admitted but remitted for fresh verification and decision in accordance with law. Case-Laws Income Tax Tue, 06 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406333