Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
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The Finance Act, 2022 amendment to section 14A applies prospectively from assessment year 2022-23 and does not govern assessment year 2018-19. Disallowance of expenditure relating to exempt income under section 14A read with rule 8D cannot exceed the exempt income earned during the relevant year. Where the taxpayer's voluntary disallowance already equalled the exempt income, no additional disallowance was warranted. The deletion of the further disallowance was sustained and the Revenue's appeal was dismissed.
The Finance Act, 2022 amendment to section 14A applies prospectively from assessment year 2022-23 and does not govern assessment year 2018-19. Disallowance of expenditure relating to exempt income under section 14A read with rule 8D cannot exceed the exempt income earned during the relevant year. Where the taxpayer's voluntary disallowance already equalled the exempt income, no additional disallowance was warranted. The deletion of the further disallowance was sustained and the Revenue's appeal was dismissed.
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