https://www.taxtmi.com/caselaws?id=242479 The Tribunal upheld the disallowance of the valuation loss on share conversion, considering it an artificial loss for tax evasion purposes. Additionally, it ruled that Rule 8D was not applicable for the relevant assessment year in determining the disallowance under section 14A, directing the AO to recompute the disallowance without invoking Rule 8D. Both the assessee's and Revenue's appeals were dismissed, emphasizing the significance of genuine commercial transactions and legitimate tax planning practices over artificial loss creation for tax evasion. en-us Wed, 05 Jun 2013 00:00:00 +0530 Thu, 16 Jan 2014 10:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=242479 The Tribunal upheld the disallowance of the valuation loss on share conversion, considering it an artificial loss for tax evasion purposes. Additionally, it ruled that Rule 8D was not applicable for the relevant assessment year in determining the disallowance under section 14A, directing the AO to recompute the disallowance without invoking Rule 8D. Both the assessee's and Revenue's appeals were dismissed, emphasizing the significance of genuine commercial transactions and legitimate tax planning practices over artificial loss creation for tax evasion. Case-Laws Income Tax Wed, 05 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=242479