https://www.taxtmi.com/caselaws?id=407622 Joint-venture balances representing accumulated shares of profits and losses, rather than actual investments capable of generating exempt income, fall outside the investment base for disallowance under section 14A read with Rule 8D(2)(iii). The disallowance was therefore deleted. A claim to restrict dividend distribution tax under the India-Thailand tax treaty may be raised as an additional ground where it is a pure legal issue arising from a subsequent legal development. However, where eligibility and treaty conditions require factual verification, the claim requires remand to the Assessing Officer for fresh examination after allowing supporting material to be filed. en-us Wed, 21 Apr 2021 00:00:00 +0530 Fri, 05 Aug 2022 15:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=407622 Joint-venture balances representing accumulated shares of profits and losses, rather than actual investments capable of generating exempt income, fall outside the investment base for disallowance under section 14A read with Rule 8D(2)(iii). The disallowance was therefore deleted. A claim to restrict dividend distribution tax under the India-Thailand tax treaty may be raised as an additional ground where it is a pure legal issue arising from a subsequent legal development. However, where eligibility and treaty conditions require factual verification, the claim requires remand to the Assessing Officer for fresh examination after allowing supporting material to be filed. Case-Laws Income Tax Wed, 21 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=407622