Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
The case concerns disallowance u/s 14A r.w.r. 8D without exempt income for A.Y. Issue of retrospective/prospective application of Section 14A explanation post Finance Act, 2022. CIT(A) upheld disallowance citing Finance Act, 2020. SC rulings state disallowance impermissible without exempt income. AO's presumptions on investment source are not legally tenable. CIT(A)'s reliance on retrospective application of Section 14A explanation is illegal. Section 14A amendment not retroactive to A.Y. 2016-17. Tribunal rules against revenue, in favor of appellant, as AO's satisfaction for disallowance was based on future dividend income presumptions, lacking legal basis.
The case concerns disallowance u/s 14A r.w.r. 8D without exempt income for A.Y. Issue of retrospective/prospective application of Section 14A explanation post Finance Act, 2022. CIT(A) upheld disallowance citing Finance Act, 2020. SC rulings state disallowance impermissible without exempt income. AO's presumptions on investment source are not legally tenable. CIT(A)'s reliance on retrospective application of Section 14A explanation is illegal. Section 14A amendment not retroactive to A.Y. 2016-17. Tribunal rules against revenue, in favor of appellant, as AO's satisfaction for disallowance was based on future dividend income presumptions, lacking legal basis.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4780
Join Channel
TaxTMI 
