Minimum Public Offer Requirements set tiered issuer-based allotment minima with mandatory staged public shareholding increases and exchange enforcemen...
Disallowance under tax law for investment expenses cannot be applied mechanically; authority must record clear reasons before increasing assessee's su...
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Disallowance under s.14A r.w. Rule 8D(2)(ii) was held impermissible because the assessee established availability of surplus own funds for making investments yielding exempt income; hence no interest disallowance could be attributed to such investments, and the disallowance was deleted. Disallowance under Rule 8D(2)(iii) was held untenable absent the AO's recorded objective satisfaction, as mandated by s.14A and settled law; the direction to recompute based on proper satisfaction was sustained. Sales tax and power subsidies were treated as capital receipts since the dominant purpose was industrial development and employment generation; addition to book profit u/s 115JB was rejected. Additional depreciation and bad-debt write-off/provision treatment (including under MAT) were allowed, and carry-forward of amalgamating company's LTC loss was upheld per the approved amalgamation scheme, resulting in dismissal of Revenue's grounds and partial dismissal of assessee's appeal. - ITAT
Disallowance under s.14A r.w. Rule 8D(2)(ii) was held impermissible because the assessee established availability of surplus own funds for making investments yielding exempt income; hence no interest disallowance could be attributed to such investments, and the disallowance was deleted. Disallowance under Rule 8D(2)(iii) was held untenable absent the AO's recorded objective satisfaction, as mandated by s.14A and settled law; the direction to recompute based on proper satisfaction was sustained. Sales tax and power subsidies were treated as capital receipts since the dominant purpose was industrial development and employment generation; addition to book profit u/s 115JB was rejected. Additional depreciation and bad-debt write-off/provision treatment (including under MAT) were allowed, and carry-forward of amalgamating company's LTC loss was upheld per the approved amalgamation scheme, resulting in dismissal of Revenue's grounds and partial dismissal of assessee's appeal. - ITAT
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