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The ITAT held that the AO's disallowance under section 14A was unsustainable as no dissatisfaction with the assessee's suo motu disallowance was recorded before invoking Rule 8D, allowing the assessee's appeal. Regarding additions under section 43CA, the tribunal found the difference between the sale price and stamp duty value within the 10% tolerance limit, negating any addition. On foreign currency translation differences, the matter was remitted to the AO for verification due to inadequate examination during assessment and appeal stages. Lastly, the tribunal upheld the CIT(A)'s confirmation of the AO's disallowance of carry-forward long-term capital loss where STT was paid, citing the risk of unverified set-offs against unrelated gains in future years.
The ITAT held that the AO's disallowance under section 14A was unsustainable as no dissatisfaction with the assessee's suo motu disallowance was recorded before invoking Rule 8D, allowing the assessee's appeal. Regarding additions under section 43CA, the tribunal found the difference between the sale price and stamp duty value within the 10% tolerance limit, negating any addition. On foreign currency translation differences, the matter was remitted to the AO for verification due to inadequate examination during assessment and appeal stages. Lastly, the tribunal upheld the CIT(A)'s confirmation of the AO's disallowance of carry-forward long-term capital loss where STT was paid, citing the risk of unverified set-offs against unrelated gains in future years.
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