Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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The Income Tax Appellate Tribunal ruled that while computing book profit u/s 115JB, adjustments u/s 14A read with Rule 8D are impermissible. However, expenditure directly incurred towards generating exempt income can be added to book profit under Explanation 1(f) to Section 115JB(2), without resorting to the amount calculated u/s 14A read with Rule 8D. The matter was remanded to the Assessing Officer to verify such expenditure. Regarding additions u/s 153A, if the year is an unabated assessment year without incriminating material, no addition can be made. However, completed assessments can be reopened u/ss 147/148, subject to conditions, following the Supreme Court's decision in Abhisar Buildwell.
The Income Tax Appellate Tribunal ruled that while computing book profit u/s 115JB, adjustments u/s 14A read with Rule 8D are impermissible. However, expenditure directly incurred towards generating exempt income can be added to book profit under Explanation 1(f) to Section 115JB(2), without resorting to the amount calculated u/s 14A read with Rule 8D. The matter was remanded to the Assessing Officer to verify such expenditure. Regarding additions u/s 153A, if the year is an unabated assessment year without incriminating material, no addition can be made. However, completed assessments can be reopened u/ss 147/148, subject to conditions, following the Supreme Court's decision in Abhisar Buildwell.
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