Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Reopening of assessment u/s 147 - Addition u/s 14A read with Rule 8D. "Reason to believe" in Section 147 means cause or justification for the competent authority to reopen assessment after four years with prior approval of jurisdictional Commissioner u/s 151, if income escaped assessment or mistake in assessment. Rule 8D, effective from 24.3.2008, prescribes methodology for determining expenditure disallowance u/s 14A for earning exempt income, applicable from AY 2007-08 onwards. Assessee obligated to provide full material disclosures. Nexus between disallowed expenditure and exempt income required. Interest on loans for investment in new company not exempt u/s 14A read with Rule 8D. Reopening valid if assessment not per law, not change of opinion. No error of law or jurisdiction by AO. Writ petitions dismissed. Statutory appeal remedy available, condonation of delay for writ petition period.
Reopening of assessment u/s 147 - Addition u/s 14A read with Rule 8D. "Reason to believe" in Section 147 means cause or justification for the competent authority to reopen assessment after four years with prior approval of jurisdictional Commissioner u/s 151, if income escaped assessment or mistake in assessment. Rule 8D, effective from 24.3.2008, prescribes methodology for determining expenditure disallowance u/s 14A for earning exempt income, applicable from AY 2007-08 onwards. Assessee obligated to provide full material disclosures. Nexus between disallowed expenditure and exempt income required. Interest on loans for investment in new company not exempt u/s 14A read with Rule 8D. Reopening valid if assessment not per law, not change of opinion. No error of law or jurisdiction by AO. Writ petitions dismissed. Statutory appeal remedy available, condonation of delay for writ petition period.
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