https://www.taxtmi.com/highlights?id=97507 No disallowance under section 14A was sustained where no exempt income arose; the DRP's deletion of the 14A addition was upheld. The DRP's deletion of the 40(a)(ia) TDS disallowance for transmission and uplinking payments to a foreign satellite entity was confirmed, the payer's TDS obligation negated on facts. Software and upgrade costs were held revenue in nature for broadcasting and the related disallowance deleted. The assessee's revised ESOP expense claim was allowed as deductible business expenditure. Multiple entities were excluded from TNMM comparables as functionally dissimilar; the question whether a corporate guarantee constitutes an international transaction was remitted to the AO/TPO for fresh examination. en-us Mon, 09 Mar 2026 07:53:19 +0530 Mon, 09 Mar 2026 07:53:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=97507 No disallowance under section 14A was sustained where no exempt income arose; the DRP's deletion of the 14A addition was upheld. The DRP's deletion of the 40(a)(ia) TDS disallowance for transmission and uplinking payments to a foreign satellite entity was confirmed, the payer's TDS obligation negated on facts. Software and upgrade costs were held revenue in nature for broadcasting and the related disallowance deleted. The assessee's revised ESOP expense claim was allowed as deductible business expenditure. Multiple entities were excluded from TNMM comparables as functionally dissimilar; the question whether a corporate guarantee constitutes an international transaction was remitted to the AO/TPO for fresh examination. Highlights Income Tax Mon, 09 Mar 2026 07:53:19 +0530 https://www.taxtmi.com/highlights?id=97507