https://www.taxtmi.com/caselaws?id=793282 ITAT Delhi held that section 14A disallowance read with Rule 8D must be restricted to investments that actually yielded exempt income, and the matter was remanded for recomputation. It deleted the notional interest addition on business advances because no actual accrual or receipt was shown. For loans advanced to subsidiaries repayable in US dollars, LIBOR was held to be the correct benchmark instead of the domestic rate. The Tribunal also upheld TNMM and the exclusion of functionally dissimilar comparables, deleted the separate adjustment on outstanding receivables where working-capital effects were already reflected, and held that section 14A disallowance could not be added back while computing book profit under section 115JB. en-us Fri, 22 May 2026 00:00:00 +0530 Wed, 10 Jun 2026 11:46:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793282 ITAT Delhi held that section 14A disallowance read with Rule 8D must be restricted to investments that actually yielded exempt income, and the matter was remanded for recomputation. It deleted the notional interest addition on business advances because no actual accrual or receipt was shown. For loans advanced to subsidiaries repayable in US dollars, LIBOR was held to be the correct benchmark instead of the domestic rate. The Tribunal also upheld TNMM and the exclusion of functionally dissimilar comparables, deleted the separate adjustment on outstanding receivables where working-capital effects were already reflected, and held that section 14A disallowance could not be added back while computing book profit under section 115JB. Case-Laws Income Tax Fri, 22 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793282