Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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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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