https://www.taxtmi.com/caselaws?id=307218 Section 14A read with Rule 8D could not be applied where no exempt income was earned, so the disallowance failed. Receipt of listed shares at nil consideration was treated as a capital receipt and was not taxable under section 56(1) in the absence of a specific charging provision, nor under section 56(2)(viia), which applies only to specified shares of unlisted companies, or section 28(iv), which requires a business-linked benefit or perquisite. The appellate authority also could not issue directions to assess the transferor, as that exceeded its jurisdiction over the appeal. The substantive tax additions and the jurisdictional objection were therefore decided in favour of the assessee. en-us Wed, 02 Mar 2022 00:00:00 +0530 Tue, 28 Mar 2023 08:01:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307218 Section 14A read with Rule 8D could not be applied where no exempt income was earned, so the disallowance failed. Receipt of listed shares at nil consideration was treated as a capital receipt and was not taxable under section 56(1) in the absence of a specific charging provision, nor under section 56(2)(viia), which applies only to specified shares of unlisted companies, or section 28(iv), which requires a business-linked benefit or perquisite. The appellate authority also could not issue directions to assess the transferor, as that exceeded its jurisdiction over the appeal. The substantive tax additions and the jurisdictional objection were therefore decided in favour of the assessee. Case-Laws Income Tax Wed, 02 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307218