https://www.taxtmi.com/caselaws?id=448015 Sufficient interest-free funds can defeat a proportionate interest disallowance under section 14A where tax-free investments are so funded, and Rule 8D applies only prospectively from assessment year 2008-09. Interest paid by an Indian branch to its head office and overseas branches was treated as not taxable in India under the India-Canada DTAA in the assessee's hands. Article 7(3) was held not to bar transfer pricing scrutiny of correspondent banking charges, so the arm's length adjustment was sustained. Recurring Revenue grounds on gross interest taxation under section 115A, expatriate salary under section 44C, and bad-debt computation under section 36(1)(vii) were rejected by following the assessee's earlier case. en-us Fri, 22 Dec 2023 00:00:00 +0530 Wed, 10 Jan 2024 10:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448015 Sufficient interest-free funds can defeat a proportionate interest disallowance under section 14A where tax-free investments are so funded, and Rule 8D applies only prospectively from assessment year 2008-09. Interest paid by an Indian branch to its head office and overseas branches was treated as not taxable in India under the India-Canada DTAA in the assessee's hands. Article 7(3) was held not to bar transfer pricing scrutiny of correspondent banking charges, so the arm's length adjustment was sustained. Recurring Revenue grounds on gross interest taxation under section 115A, expatriate salary under section 44C, and bad-debt computation under section 36(1)(vii) were rejected by following the assessee's earlier case. Case-Laws Income Tax Fri, 22 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448015