Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
