Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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The ITAT Raipur ruled on disallowance u/s 14A r.w.r. 8D regarding expenditure on exempt income. The assessee argued that no disallowance of interest expenditure claimed as deduction was warranted as it had sufficient self-owned funds for exempt income investments. The AO mechanically applied Rule 8D(2)(ii) for disallowance without proper satisfaction on the claim. The AO's general observations did not meet the legal requirement for a valid determination. The tribunal set aside the CIT(A)'s decision to uphold the disallowance, ruling in favor of the assessee due to the AO's failure to meet statutory obligations in assessing the claim.
The ITAT Raipur ruled on disallowance u/s 14A r.w.r. 8D regarding expenditure on exempt income. The assessee argued that no disallowance of interest expenditure claimed as deduction was warranted as it had sufficient self-owned funds for exempt income investments. The AO mechanically applied Rule 8D(2)(ii) for disallowance without proper satisfaction on the claim. The AO's general observations did not meet the legal requirement for a valid determination. The tribunal set aside the CIT(A)'s decision to uphold the disallowance, ruling in favor of the assessee due to the AO's failure to meet statutory obligations in assessing the claim.
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