Corporate guarantee commission and book profit computation require fact-based allocation and fresh recomputation after Section 14A exclusion

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....Corporate guarantee commission under the interest saving method required allocation of the benefit between guarantor and borrower; in the absence of fuller facts, the Tribunal directed a 50:50 split and clarified that this is fact-specific, not a universal rule. Book profit computation could not be increased by the Section 14A disallowance in the manner adopted by the Assessing Officer; following Vireet Investment, the figure had to be recomputed under clause (f) of Explanation 1 without applying Rule 8D. For the set-aside years, the Assessing Officer was also directed to verify the assessment records, consider the assessee's submissions, and recompute total income after giving effect to earlier reliefs.....