https://www.taxtmi.com/caselaws?id=446456 A debt-free assessee may resist a section 14A read with Rule 8D(2)(iii) disallowance where no borrowed funds were used and no causal nexus with exempt income is shown. Outstanding receivables from associated enterprises do not automatically justify a notional interest adjustment; the transfer pricing treatment depends on the factual and transactional context, including whether the receivables amount to a separate international transaction. Comparability exclusions based on functional dissimilarity and lack of segmental data remain factual determinations and ordinarily do not raise a substantial question of law. en-us Mon, 04 Dec 2023 00:00:00 +0530 Wed, 18 Feb 2026 16:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446456 A debt-free assessee may resist a section 14A read with Rule 8D(2)(iii) disallowance where no borrowed funds were used and no causal nexus with exempt income is shown. Outstanding receivables from associated enterprises do not automatically justify a notional interest adjustment; the transfer pricing treatment depends on the factual and transactional context, including whether the receivables amount to a separate international transaction. Comparability exclusions based on functional dissimilarity and lack of segmental data remain factual determinations and ordinarily do not raise a substantial question of law. Case-Laws Income Tax Mon, 04 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446456