https://www.taxtmi.com/caselaws?id=759924 Where the assessee had substantial interest-free funds, investments yielding exempt income were treated as made from own funds, so section 14A disallowance was confined only to a limited ad hoc amount. Business expenditure on vacating tenant premises, deferred guarantee commission, and employee separation costs was treated as revenue in nature and allowed, while expatriate salary and NRI mobilisation expenses were largely regarded as deductible India-specific costs, subject only to proportionate disallowance for overseas functions and the statutory section 44C ceiling. Overfunding of gratuity and pension funds, and reversal of pension provision, were not taxed again because no remission or double addition arose. Transfer pricing adjustments on group support and USD placement were rejected where incidental services were not separately benchmarkable and CUP benchmarking was accepted. en-us Tue, 30 Apr 2024 00:00:00 +0530 Thu, 10 Oct 2024 15:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759924 Where the assessee had substantial interest-free funds, investments yielding exempt income were treated as made from own funds, so section 14A disallowance was confined only to a limited ad hoc amount. Business expenditure on vacating tenant premises, deferred guarantee commission, and employee separation costs was treated as revenue in nature and allowed, while expatriate salary and NRI mobilisation expenses were largely regarded as deductible India-specific costs, subject only to proportionate disallowance for overseas functions and the statutory section 44C ceiling. Overfunding of gratuity and pension funds, and reversal of pension provision, were not taxed again because no remission or double addition arose. Transfer pricing adjustments on group support and USD placement were rejected where incidental services were not separately benchmarkable and CUP benchmarking was accepted. Case-Laws Income Tax Tue, 30 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759924