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Suo motu disallowance claimed in the return relating to...
Disallowance under tax law for investment expenses cannot be applied mechanically; authority must record clear reasons before increasing assessee's suo motu deduction.
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Suo motu disallowance claimed in the return relating to investment-related expenses cannot be rejected mechanically; the tax authority must record clear findings explaining why the assessee's suo motu disallowance and the supporting accountant's report are unacceptable and must demonstrate bona fide satisfaction and objective reasons before invoking the disallowance rule beyond the assessee's amount. Prior precedent on identical questions precluded reopening those issues, and the appellate tribunal's restriction on additional disallowance was upheld. The appeal was dismissed to the extent the earlier rulings governed the same questions.
Suo motu disallowance claimed in the return relating to investment-related expenses cannot be rejected mechanically; the tax authority must record clear findings explaining why the assessee's suo motu disallowance and the supporting accountant's report are unacceptable and must demonstrate bona fide satisfaction and objective reasons before invoking the disallowance rule beyond the assessee's amount. Prior precedent on identical questions precluded reopening those issues, and the appellate tribunal's restriction on additional disallowance was upheld. The appeal was dismissed to the extent the earlier rulings governed the same questions.
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