https://www.taxtmi.com/caselaws?id=439242 The dominant issues were the validity of admitting additional evidence, tax treatment of compensation, disallowance under s.14A r.w. Rule 8D, employees' PF/ESI deposits, and deduction under s.80IB for a new unit. The ITAT upheld the CIT(A)'s admission of additional evidence as crucial and procedurally compliant, so Revenue's challenge failed. On s.14A, since the AO neither found the assessee's suo motu disallowance defective nor recorded satisfaction under s.14A(2) before invoking Rule 8D, disallowance was restricted to the assessee's self-disallowance, against Revenue. Compensation was held to be a capital receipt (liquidated damages impairing a bundle of rights), not STCG under s.55(2)(a), against Revenue. PF/ESI late deposits were disallowed following SC, against the assessee. The s.80IB deduction was allowed as AO lacked foundational facts and profit-shifting was not established, against Revenue. en-us Fri, 16 Jun 2023 00:00:00 +0530 Mon, 05 Jan 2026 12:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439242 The dominant issues were the validity of admitting additional evidence, tax treatment of compensation, disallowance under s.14A r.w. Rule 8D, employees' PF/ESI deposits, and deduction under s.80IB for a new unit. The ITAT upheld the CIT(A)'s admission of additional evidence as crucial and procedurally compliant, so Revenue's challenge failed. On s.14A, since the AO neither found the assessee's suo motu disallowance defective nor recorded satisfaction under s.14A(2) before invoking Rule 8D, disallowance was restricted to the assessee's self-disallowance, against Revenue. Compensation was held to be a capital receipt (liquidated damages impairing a bundle of rights), not STCG under s.55(2)(a), against Revenue. PF/ESI late deposits were disallowed following SC, against the assessee. The s.80IB deduction was allowed as AO lacked foundational facts and profit-shifting was not established, against Revenue. Case-Laws Income Tax Fri, 16 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439242