https://www.taxtmi.com/caselaws?id=308761 Section 14A disallowance cannot exceed exempt dividend income, and an assessee may seek reduction to the amount legally sustainable despite a higher suo motu offer. Book profit under section 115JB must be computed independently under Explanation 1, without importing the section 14A read with Rule 8D disallowance mechanism. Corporate guarantee to an associated enterprise is an international transaction, but the arm's length commission was taken at 0.5%, with the assessee's co-guarantor share fixed at 0.25%. Under the tonnage tax scheme, ship management income and interest on ship acquisition were held to be part of the presumptive code, so separate transfer pricing adjustments were deleted. en-us Mon, 06 Jan 2020 00:00:00 +0530 Wed, 19 Jul 2023 20:59:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308761 Section 14A disallowance cannot exceed exempt dividend income, and an assessee may seek reduction to the amount legally sustainable despite a higher suo motu offer. Book profit under section 115JB must be computed independently under Explanation 1, without importing the section 14A read with Rule 8D disallowance mechanism. Corporate guarantee to an associated enterprise is an international transaction, but the arm's length commission was taken at 0.5%, with the assessee's co-guarantor share fixed at 0.25%. Under the tonnage tax scheme, ship management income and interest on ship acquisition were held to be part of the presumptive code, so separate transfer pricing adjustments were deleted. Case-Laws Income Tax Mon, 06 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308761