Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Rule 8D can be applied for exempt-income disallowance only after the Assessing Officer examines the assessee's accounts and records why the claim of lesser or no expenditure is incorrect under section 14A(2). The text says the officer rejected the claim merely for want of evidence, without identifying the missing material, analysing the cash-flow and fund-flow in the audited accounts, or linking borrowed funds, interest expenditure, or specific administrative to the exempt investments. The appellate authority also did not address this statutory defect. The further disallowance under Rule 8D was therefore treated as unsustainable and was confined to the assessee's voluntary disallowance.
Rule 8D can be applied for exempt-income disallowance only after the Assessing Officer examines the assessee's accounts and records why the claim of lesser or no expenditure is incorrect under section 14A(2). The text says the officer rejected the claim merely for want of evidence, without identifying the missing material, analysing the cash-flow and fund-flow in the audited accounts, or linking borrowed funds, interest expenditure, or specific administrative to the exempt investments. The appellate authority also did not address this statutory defect. The further disallowance under Rule 8D was therefore treated as unsustainable and was confined to the assessee's voluntary disallowance.
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