Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
ITAT dismissed the appeal, upholding the disallowance under section 14A read with Rule 8D. The Tribunal found the AO validly computed disallowance under Rule 8D(2)(ii) on investments alone, notwithstanding absence of a proportional interest disallowance, and rejected the assessee's challenge to the AO's application of mind and alleged failure to record satisfaction. The Tribunal further held that, post-amendment, the assessee was obliged to compute suo moto disallowance even if no exempt income arose, which it failed to do. No infirmity was found in the CIT(A)'s order; the AO's computation under Rule 8D was affirmed and the assessee's appeal dismissed.
ITAT dismissed the appeal, upholding the disallowance under section 14A read with Rule 8D. The Tribunal found the AO validly computed disallowance under Rule 8D(2)(ii) on investments alone, notwithstanding absence of a proportional interest disallowance, and rejected the assessee's challenge to the AO's application of mind and alleged failure to record satisfaction. The Tribunal further held that, post-amendment, the assessee was obliged to compute suo moto disallowance even if no exempt income arose, which it failed to do. No infirmity was found in the CIT(A)'s order; the AO's computation under Rule 8D was affirmed and the assessee's appeal dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
