SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
The ITAT held that disallowance u/s 14A r/w rule 8D was not justified as the AO did not record dissatisfaction u/s 14A(2) before invoking Rule 8D. The disallowance of the Assessing Officer was not sustainable as the investments did not generate exempt income. Regarding deduction u/s 37 for education cess, the retrospective amendment to Sec. 40(a)(ii) by the Finance Act, 2022 was discussed. The assessee can withdraw the claim subject to paying taxes if application in Form No.69 is made within the prescribed period. The AO must address the application made by the assessee as per the directions given by the ITAT.
The ITAT held that disallowance u/s 14A r/w rule 8D was not justified as the AO did not record dissatisfaction u/s 14A(2) before invoking Rule 8D. The disallowance of the Assessing Officer was not sustainable as the investments did not generate exempt income. Regarding deduction u/s 37 for education cess, the retrospective amendment to Sec. 40(a)(ii) by the Finance Act, 2022 was discussed. The assessee can withdraw the claim subject to paying taxes if application in Form No.69 is made within the prescribed period. The AO must address the application made by the assessee as per the directions given by the ITAT.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
