Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
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Whether disallowance under section 14A read with Rule 8D required prior recording of satisfaction: held that s.14A(2) mandates that the assessing officer must record satisfaction or dissatisfaction regarding the correctness of expenditure claimed before making an addition; absence of such recorded dissatisfaction renders the disallowance impermissible. Applying this legal precondition, the Tribunal and the appellate tax authority's factual findings rejecting the Revenue's adjustment were upheld and the Revenue's appeal dismissed. - HC
Whether disallowance under section 14A read with Rule 8D required prior recording of satisfaction: held that s.14A(2) mandates that the assessing officer must record satisfaction or dissatisfaction regarding the correctness of expenditure claimed before making an addition; absence of such recorded dissatisfaction renders the disallowance impermissible. Applying this legal precondition, the Tribunal and the appellate tax authority's factual findings rejecting the Revenue's adjustment were upheld and the Revenue's appeal dismissed. - HC
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