https://www.taxtmi.com/caselaws?id=420202 Relief by way of foreign tax credit under the India-Oman DTAA did not convert dividend income from the assessee's foreign PE into exempt income for section 14A purposes, so disallowance under section 14A read with rule 8D was unsustainable and was deleted. On horticulture expenses, the tribunal held that a presumptive 10% disallowance for possible personal use, based only on the absence of a premise-wise or employee-wise log book, was not justified where the assessee showed the expenditure related to green belts and township maintenance and no specific material established personal use. The Revenue's challenge failed on both issues and the additions were sustained as deleted. en-us Fri, 25 Mar 2022 00:00:00 +0530 Mon, 28 Mar 2022 10:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=420202 Relief by way of foreign tax credit under the India-Oman DTAA did not convert dividend income from the assessee's foreign PE into exempt income for section 14A purposes, so disallowance under section 14A read with rule 8D was unsustainable and was deleted. On horticulture expenses, the tribunal held that a presumptive 10% disallowance for possible personal use, based only on the absence of a premise-wise or employee-wise log book, was not justified where the assessee showed the expenditure related to green belts and township maintenance and no specific material established personal use. The Revenue's challenge failed on both issues and the additions were sustained as deleted. Case-Laws Income Tax Fri, 25 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=420202