Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
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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