https://www.taxtmi.com/caselaws?id=464566 ITAT MUMBAI (AT) held that disallowance under s.14A/rule 8D is not permissible where no exempt income (dividend) is claimed and upheld CIT(A)'s finding of adequate own funds. The tribunal affirmed deletion of notional income for lower guarantee commission, finding the charged 0.75% reasonable. Foreign-exchange forward contract losses were held business losses (not speculative) as contracts matched export orders. Payments of export agent commission and overseas warehousing charges to non-residents were held not taxable in India, so s.40(a)(i) addition was denied. Late employee EPF contributions were allowed where paid before filing the return; revenue grounds were dismissed. en-us Mon, 21 Feb 2022 00:00:00 +0530 Tue, 04 Nov 2025 20:06:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464566 ITAT MUMBAI (AT) held that disallowance under s.14A/rule 8D is not permissible where no exempt income (dividend) is claimed and upheld CIT(A)'s finding of adequate own funds. The tribunal affirmed deletion of notional income for lower guarantee commission, finding the charged 0.75% reasonable. Foreign-exchange forward contract losses were held business losses (not speculative) as contracts matched export orders. Payments of export agent commission and overseas warehousing charges to non-residents were held not taxable in India, so s.40(a)(i) addition was denied. Late employee EPF contributions were allowed where paid before filing the return; revenue grounds were dismissed. Case-Laws Income Tax Mon, 21 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464566