Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
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 4884 
