Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
