https://www.taxtmi.com/caselaws?id=294686 Rule 8D was applied prospectively from assessment year 2008-09, so a Section 14A disallowance based solely on that Rule could not survive for assessment year 2007-08, while later years' formula-based disallowances were sustained. Commission paid to non-resident agents for procuring business abroad was treated as non-taxable in India because it was not managerial, technical or consultancy income, the agents carried on no operations in India, and no withholding was required under Section 195; the related Section 40(a)(i) disallowance therefore failed. VAT refund was not taxable where the underlying expenditure had not been claimed as a deduction, and the brought-forward business loss set-off issue was left for factual verification. en-us Thu, 21 Sep 2017 00:00:00 +0530 Wed, 28 Apr 2021 11:51:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=294686 Rule 8D was applied prospectively from assessment year 2008-09, so a Section 14A disallowance based solely on that Rule could not survive for assessment year 2007-08, while later years' formula-based disallowances were sustained. Commission paid to non-resident agents for procuring business abroad was treated as non-taxable in India because it was not managerial, technical or consultancy income, the agents carried on no operations in India, and no withholding was required under Section 195; the related Section 40(a)(i) disallowance therefore failed. VAT refund was not taxable where the underlying expenditure had not been claimed as a deduction, and the brought-forward business loss set-off issue was left for factual verification. Case-Laws Income Tax Thu, 21 Sep 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=294686