Section 14A disallowance restricted to 2% of exempt income due to inapplicability of Rule 8D for the...

Section 14A disallowance restricted to 2% of exempt income due to inapplicability of Rule 8D for the relevant assessment year. TDS disallowance u/s 40(a)(ia) upheld for payments to Team Lease for providing staff on contractual basis. Disallowance u/s 40(a)(i) for global overhead charges paid to Deutsche Securities Inc., New York deleted as payments not taxable as fees for included services under India-USA tax treaty. TPO/AO directed to recompute arm's length price after granting volume and marketing cost adjustment. Education cess disallowance upheld due to retrospective amendment. Disallowance u/s 40(a)(ia) for VSAT/lease line charges and transaction charges paid to stock exchanges deleted as not fees for technical services. Benefit of 5% variation u/s 92C(2) denied as per Special Bench ruling. .....

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