https://www.taxtmi.com/caselaws?id=312553 The ITAT Chennai held that for AY 2007-08, Rule 8D provisions were not applicable, directing AO to disallow only 5% of dividend income under section 14A for normal computation while no disallowance should be made under section 115JB. Foreign exchange loss on interest for asset acquisition was properly capitalized under section 43A with depreciation benefit allowed, but such capitalization cannot apply under section 115JB due to legal fiction. Addition regarding provision for bad debts was upheld as no deduction is available under the Act, and Explanation I(c)(i) to section 115JB requires increasing book profit by such provisions. The transfer pricing adjustment matter concerning commission paid to associated enterprises for marketing services was remitted back to TPO for fresh consideration. en-us Wed, 13 Jul 2016 00:00:00 +0530 Sat, 24 Feb 2024 06:29:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312553 The ITAT Chennai held that for AY 2007-08, Rule 8D provisions were not applicable, directing AO to disallow only 5% of dividend income under section 14A for normal computation while no disallowance should be made under section 115JB. Foreign exchange loss on interest for asset acquisition was properly capitalized under section 43A with depreciation benefit allowed, but such capitalization cannot apply under section 115JB due to legal fiction. Addition regarding provision for bad debts was upheld as no deduction is available under the Act, and Explanation I(c)(i) to section 115JB requires increasing book profit by such provisions. The transfer pricing adjustment matter concerning commission paid to associated enterprises for marketing services was remitted back to TPO for fresh consideration. Case-Laws Income Tax Wed, 13 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312553