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...
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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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