https://www.taxtmi.com/caselaws?id=470857 Unallotted share application money made available to an associated enterprise beyond a reasonable period, and trade receivables extended beyond six months, may constitute international transactions; notional interest on foreign-currency remittances should be benchmarked to LIBOR rather than Indian bank PLR. Captive software development providers should not be compared with companies having significant brand value, product revenue, diversification, restructuring, exceptional scale or unavailable segmental results, and negative working-capital adjustments are inappropriate where the provider bears no working-capital risk. Section 14A disallowance is capped at exempt income, section 10A deduction is computed undertaking-wise before loss set-off, and commercially expedient club-membership expenditure is deductible. Depreciation, capital-gains, TDS-credit and distributed-profit interest claims require factual verification. en-us Wed, 29 Jan 2020 00:00:00 +0530 Tue, 11 Aug 2026 18:40:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470857 Unallotted share application money made available to an associated enterprise beyond a reasonable period, and trade receivables extended beyond six months, may constitute international transactions; notional interest on foreign-currency remittances should be benchmarked to LIBOR rather than Indian bank PLR. Captive software development providers should not be compared with companies having significant brand value, product revenue, diversification, restructuring, exceptional scale or unavailable segmental results, and negative working-capital adjustments are inappropriate where the provider bears no working-capital risk. Section 14A disallowance is capped at exempt income, section 10A deduction is computed undertaking-wise before loss set-off, and commercially expedient club-membership expenditure is deductible. Depreciation, capital-gains, TDS-credit and distributed-profit interest claims require factual verification. Case-Laws Income Tax Wed, 29 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470857