Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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Disallowance under section 14A was confined to the exempt income actually earned, because the Tribunal followed the binding Delhi High Court view that such disallowance cannot exceed the exempt income. The assessee had earned exempt income, while the Assessing Officer computed a higher amount under Rule 8D; the Tribunal restricted the disallowance to the exempt income amount. It also held that the Explanation inserted in section 14A by the Finance Act, 2022 operates prospectively and did not apply to Assessment Year 2017-18. The appeal was partly allowed and the disallowance was restricted accordingly.
Disallowance under section 14A was confined to the exempt income actually earned, because the Tribunal followed the binding Delhi High Court view that such disallowance cannot exceed the exempt income. The assessee had earned exempt income, while the Assessing Officer computed a higher amount under Rule 8D; the Tribunal restricted the disallowance to the exempt income amount. It also held that the Explanation inserted in section 14A by the Finance Act, 2022 operates prospectively and did not apply to Assessment Year 2017-18. The appeal was partly allowed and the disallowance was restricted accordingly.
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