Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
In the case before ITAT Chennai, the issue of disallowance u/s 14A r.w.r. 8D was considered. The CIT(A) found that no exempt income was earned by the assessee, leading to full relief being granted. The order of the CIT(A) and AO regarding disallowance was set aside, directing the AO to delete the addition from the total income. Regarding TDS u/s 195 for listing charges paid to Bank of New York, it was noted that DTAA provisions were not considered. The AO was directed to re-examine the issue in light of DTAA provisions. The claim of prior period expenditure was dismissed as it cannot be allowed in the assessment of a specific year. The writing off of carbon income was remanded to the AO for re-examination based on past treatment by the Department. The issue was decided in favor of the assessee for statistical purposes only.
In the case before ITAT Chennai, the issue of disallowance u/s 14A r.w.r. 8D was considered. The CIT(A) found that no exempt income was earned by the assessee, leading to full relief being granted. The order of the CIT(A) and AO regarding disallowance was set aside, directing the AO to delete the addition from the total income. Regarding TDS u/s 195 for listing charges paid to Bank of New York, it was noted that DTAA provisions were not considered. The AO was directed to re-examine the issue in light of DTAA provisions. The claim of prior period expenditure was dismissed as it cannot be allowed in the assessment of a specific year. The writing off of carbon income was remanded to the AO for re-examination based on past treatment by the Department. The issue was decided in favor of the assessee for statistical purposes only.
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