Introducing the “In Favour Of” filter in Case Laws.
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Introducing the “In Favour Of” filter in Case Laws.
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of The ITAT Raipur held that no disallowance of interest expenditure was warranted u/s 14A as the assessee had sufficient self-owned funds. Citing the Bombay High Court and Supreme Court judgments, it was established that if the assessee had non-interest bearing funds larger than investments in tax-free securities, no disallowance was required. However, disallowance of administrative expenditure u/s 14A r.w.r. 8D(2)(iii) was upheld due to lack of plausible explanation. Regarding addition u/s 41(1) for cessation of liability, the ITAT found no justification for the addition of Rs. 10,00,000 and directed the AO to re-adjudicate the matter with an opportunity for the assessee to substantiate the claim. The decline of credit of TCS for the purchase of coal was deemed appropriate as the transaction occurred in the succeeding year, and the credit should be claimed in the subsequent year's return. The AO was directed to allow the credit of TCS in the next assessment year.
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