https://www.taxtmi.com/caselaws?id=775956 The ITAT Delhi upheld the disallowance under section 36(1)(iii) was not warranted as the assessee had sufficient own funds and no evidence showed loans to subsidiaries lacked commercial expediency. The tribunal relied on SC precedent confirming investments presumed from interest-free funds when available. Disallowance under section 14A read with Rule 8D was directed to be reconsidered by the AO only if exempt income existed; otherwise, no disallowance was to be made. The CIT(A)'s deletion of TP adjustment on AMP expenses was upheld, as the adjustment was limited per the APA methodology. The deletion of addition for excess director remuneration was also affirmed since payments were approved by the Government before the financial year-end. The appeals were allowed in part and against the Revenue in others. en-us Thu, 31 Jul 2025 00:00:00 +0530 Sat, 02 Aug 2025 07:24:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775956 The ITAT Delhi upheld the disallowance under section 36(1)(iii) was not warranted as the assessee had sufficient own funds and no evidence showed loans to subsidiaries lacked commercial expediency. The tribunal relied on SC precedent confirming investments presumed from interest-free funds when available. Disallowance under section 14A read with Rule 8D was directed to be reconsidered by the AO only if exempt income existed; otherwise, no disallowance was to be made. The CIT(A)'s deletion of TP adjustment on AMP expenses was upheld, as the adjustment was limited per the APA methodology. The deletion of addition for excess director remuneration was also affirmed since payments were approved by the Government before the financial year-end. The appeals were allowed in part and against the Revenue in others. Case-Laws Income Tax Thu, 31 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775956