Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
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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TaxTMI 
TaxTMI 
of 4894 
