https://www.taxtmi.com/caselaws?id=750725 Tax-free bond investments funded by sufficient own funds did not attract a proportionate disallowance under section 14A read with rule 8D, and salary paid to expatriate employees seconded to Indian branches was not treated as head office expenditure under section 44C because the services were rendered wholly for Indian operations. Interest income from foreign currency loans followed the assessee's earlier-year treatment, interest paid by the Indian branch to head office/overseas branches remained deductible on the same facts, and the transfer pricing adjustment for inter-bank indemnity or guarantee services was deleted because CUP benchmarking lacked reliable comparables and TNMM was accepted as the appropriate method. en-us Mon, 29 Jan 2024 00:00:00 +0530 Thu, 28 Mar 2024 10:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=750725 Tax-free bond investments funded by sufficient own funds did not attract a proportionate disallowance under section 14A read with rule 8D, and salary paid to expatriate employees seconded to Indian branches was not treated as head office expenditure under section 44C because the services were rendered wholly for Indian operations. Interest income from foreign currency loans followed the assessee's earlier-year treatment, interest paid by the Indian branch to head office/overseas branches remained deductible on the same facts, and the transfer pricing adjustment for inter-bank indemnity or guarantee services was deleted because CUP benchmarking lacked reliable comparables and TNMM was accepted as the appropriate method. Case-Laws Income Tax Mon, 29 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=750725