https://www.taxtmi.com/caselaws?id=802391 Before assessment year 2022-23, section 14A does not permit disallowance where no exempt income is earned; the Finance Act 2022 amendments do not apply retrospectively. Transfer-pricing comparability considers turnover, functional differences, segmental data and reliable margins. Direct expenses are attributed to the relevant segment, while common expenses may be allocated by segmental revenue. Foreign-currency receivables may be benchmarked using LIBOR plus 200 basis points after a 30-day credit period. Professional services expenditure is assessed for business purpose under section 37. Goodwill arising on amalgamation from consideration exceeding net assets acquired may qualify for depreciation where the Finance Act 2021 exclusion does not apply to the relevant assessment year. en-us Fri, 11 Sep 2026 00:00:00 +0530 Thu, 05 Nov 2026 07:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=802391 Before assessment year 2022-23, section 14A does not permit disallowance where no exempt income is earned; the Finance Act 2022 amendments do not apply retrospectively. Transfer-pricing comparability considers turnover, functional differences, segmental data and reliable margins. Direct expenses are attributed to the relevant segment, while common expenses may be allocated by segmental revenue. Foreign-currency receivables may be benchmarked using LIBOR plus 200 basis points after a 30-day credit period. Professional services expenditure is assessed for business purpose under section 37. Goodwill arising on amalgamation from consideration exceeding net assets acquired may qualify for depreciation where the Finance Act 2021 exclusion does not apply to the relevant assessment year. Case-Laws Income Tax Fri, 11 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=802391