Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
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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