https://www.taxtmi.com/caselaws?id=800888 Manufacturing scrap generated directly through eligible units' production qualifies for the profit-linked deduction. Further expenditure disallowance under section 14A and Rule 8D requires recorded satisfaction, based on the accounts, that a voluntary disallowance is inadequate; no additional disallowance is warranted where the voluntary amount exceeds exempt dividend income. Corporate guarantees for associated enterprises are international transactions, with the guarantee fee restricted to 0.35%. Equity investments at a premium cannot be recharacterised as deemed interest-free loans. Consistently applied incremental allocation of common expenses is accepted where separate books capture direct costs. Royalty benchmarking requires fresh determination after disclosure of the comparable-search strategy and an opportunity of hearing. en-us Tue, 22 Sep 2026 00:00:00 +0530 Tue, 13 Oct 2026 07:21:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800888 Manufacturing scrap generated directly through eligible units' production qualifies for the profit-linked deduction. Further expenditure disallowance under section 14A and Rule 8D requires recorded satisfaction, based on the accounts, that a voluntary disallowance is inadequate; no additional disallowance is warranted where the voluntary amount exceeds exempt dividend income. Corporate guarantees for associated enterprises are international transactions, with the guarantee fee restricted to 0.35%. Equity investments at a premium cannot be recharacterised as deemed interest-free loans. Consistently applied incremental allocation of common expenses is accepted where separate books capture direct costs. Royalty benchmarking requires fresh determination after disclosure of the comparable-search strategy and an opportunity of hearing. Case-Laws Income Tax Tue, 22 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800888