https://www.taxtmi.com/caselaws?id=794456 Disallowance under section 14A is restricted to the exempt income earned where the jurisdictional view requires that cap, notwithstanding Rule 8D or a CBDT circular. For transfer pricing of management support services, comparables must demonstrate functional similarity and be supported by reliable year-specific public information. Companies engaged in digital-certificate trading or liaison activities, or whose business profile and relevant data are insufficiently available, are unsuitable comparables. Accordingly, the section 14A disallowance was confined to exempt income, and the two disputed companies were excluded from the comparable set. en-us Mon, 08 Jun 2026 00:00:00 +0530 Mon, 06 Jul 2026 08:26:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794456 Disallowance under section 14A is restricted to the exempt income earned where the jurisdictional view requires that cap, notwithstanding Rule 8D or a CBDT circular. For transfer pricing of management support services, comparables must demonstrate functional similarity and be supported by reliable year-specific public information. Companies engaged in digital-certificate trading or liaison activities, or whose business profile and relevant data are insufficiently available, are unsuitable comparables. Accordingly, the section 14A disallowance was confined to exempt income, and the two disputed companies were excluded from the comparable set. Case-Laws Income Tax Mon, 08 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794456