Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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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