Revenue authority mandates using scheme-specific reversal procedures, not revising original entries, for instrument-based trade/customs benefits effec...
Transaction value under s.15(1) governs unrelated sales; valuation between related parties per Rule 28; consignment note required for unregistered rec...
ITAT dismissed the revenue's appeal and upheld the CIT(A)'s allowance of the assessee's claim under section 14A read with r.w.r. 8D. The Tribunal found the AO's suo-moto disallowance unreasonable and procedurally defective because no contemporaneous satisfaction was recorded to justify overriding the assessee's self-disallowance, and the AO failed to segregate investments yielding exempt income. The AO's computation, which exceeded total P&L expenses and ignored the assessee's working confined to investments producing exempt income, was held to lack logical basis and factual appreciation. Consequently, the excess disallowance imposed by the AO was deleted and the revenue's appeal dismissed.
ITAT dismissed the revenue's appeal and upheld the CIT(A)'s allowance of the assessee's claim under section 14A read with r.w.r. 8D. The Tribunal found the AO's suo-moto disallowance unreasonable and procedurally defective because no contemporaneous satisfaction was recorded to justify overriding the assessee's self-disallowance, and the AO failed to segregate investments yielding exempt income. The AO's computation, which exceeded total P&L expenses and ignored the assessee's working confined to investments producing exempt income, was held to lack logical basis and factual appreciation. Consequently, the excess disallowance imposed by the AO was deleted and the revenue's appeal dismissed.
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