Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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.
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