Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
Disallowance under section 14A/Rule 8D: Rule 8D disallowance must be computed only with reference to investments that actually yielded exempt income, and AO is directed to recompute disallowance at 1% of the monthly average of those exempt-income-yielding investments - disallowance restricted accordingly. Disallowance added to book profit u/s 115JB: Clause (f) of Explanation 1 to s.115JB is to be computed without applying s.14A/Rule 8D, therefore the 14A addition to book profit is deleted. Interest on borrowings for interest-free advances: where own non-interest funds cover advances, no disallowance of borrowed interest - addition deleted. Vastu payments/depreciation: recurring large payments not for business purpose - addition upheld (disallowed). Government subsidy: treated as income under amended law - appeal dismissed. Royalty: deductible only on actual payment under s.43B - confirmed. Leave-encashment provision for 115JB: remitted to AO to decide under Explanation (1). Interest on belated TDS: allowed in computing book profit. 80IA transfer-pricing adjustment: deleted. SBN deposits u/s 68: remitted to AO for verification; matter allowed for statistical purposes. - ITAT
Disallowance under section 14A/Rule 8D: Rule 8D disallowance must be computed only with reference to investments that actually yielded exempt income, and AO is directed to recompute disallowance at 1% of the monthly average of those exempt-income-yielding investments - disallowance restricted accordingly. Disallowance added to book profit u/s 115JB: Clause (f) of Explanation 1 to s.115JB is to be computed without applying s.14A/Rule 8D, therefore the 14A addition to book profit is deleted. Interest on borrowings for interest-free advances: where own non-interest funds cover advances, no disallowance of borrowed interest - addition deleted. Vastu payments/depreciation: recurring large payments not for business purpose - addition upheld (disallowed). Government subsidy: treated as income under amended law - appeal dismissed. Royalty: deductible only on actual payment under s.43B - confirmed. Leave-encashment provision for 115JB: remitted to AO to decide under Explanation (1). Interest on belated TDS: allowed in computing book profit. 80IA transfer-pricing adjustment: deleted. SBN deposits u/s 68: remitted to AO for verification; matter allowed for statistical purposes. - ITAT
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