Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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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