https://www.taxtmi.com/highlights?id=100779 Short deduction of tax at source did not warrant disallowance under section 40(a)(ia), and the related royalty-characterisation questions were treated as academic. Corporate guarantee commission was upheld at 0.5% because a corporate guarantee to an associated enterprise is not comparable to a bank guarantee, so no substantial question of law arose. On section 14A, where the assessee's own and other non-interest-bearing funds exceeded tax-free investments, a presumption arose that the investments came from interest-free funds, defeating interest disallowance under Rule 8D(2)(ii). Only the re-framed question under section 14A read with Rule 8D(2)(iii) concerning investments yielding exempt income during the year was entertained. en-us Mon, 15 Jun 2026 09:09:35 +0530 Mon, 15 Jun 2026 09:09:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=100779 Short deduction of tax at source did not warrant disallowance under section 40(a)(ia), and the related royalty-characterisation questions were treated as academic. Corporate guarantee commission was upheld at 0.5% because a corporate guarantee to an associated enterprise is not comparable to a bank guarantee, so no substantial question of law arose. On section 14A, where the assessee's own and other non-interest-bearing funds exceeded tax-free investments, a presumption arose that the investments came from interest-free funds, defeating interest disallowance under Rule 8D(2)(ii). Only the re-framed question under section 14A read with Rule 8D(2)(iii) concerning investments yielding exempt income during the year was entertained. Highlights Income Tax Mon, 15 Jun 2026 09:09:35 +0530 https://www.taxtmi.com/highlights?id=100779