https://www.taxtmi.com/caselaws?id=417266 Disallowance under Section 14A was unsustainable because the Assessing Officer had not first recorded the statutory satisfaction required before invoking Rule 8D; the addition was deleted. Refunds of CENVAT credit under the Jammu incentive scheme and VAT under the Uttar Pradesh industrial incentive scheme were held to be capital receipts, as the schemes' object was to promote industrialisation, capital investment and employment. As capital receipts not chargeable to tax, both refunds were excluded from book profit under Section 115JB. The assessee succeeded on all substantive issues. en-us Tue, 30 Nov 2021 00:00:00 +0530 Wed, 19 Jan 2022 13:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=417266 Disallowance under Section 14A was unsustainable because the Assessing Officer had not first recorded the statutory satisfaction required before invoking Rule 8D; the addition was deleted. Refunds of CENVAT credit under the Jammu incentive scheme and VAT under the Uttar Pradesh industrial incentive scheme were held to be capital receipts, as the schemes' object was to promote industrialisation, capital investment and employment. As capital receipts not chargeable to tax, both refunds were excluded from book profit under Section 115JB. The assessee succeeded on all substantive issues. Case-Laws Income Tax Tue, 30 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=417266