https://www.taxtmi.com/caselaws?id=445443 ITAT Pune held that sale consideration of Rs. 85.79 crore received by assessee on share transfer was not exclusively for shares but also included value for negative covenants, given assessee's indemnity liability up to Rs. 40 crore. The tribunal directed AO to segregate consideration between share transfer (taxable as capital gains) and negative covenants (taxable as business income under section 28(va)). Disallowance under section 14A was upheld as AO correctly applied rule 8D(2)(iii) considering only exempt income yielding securities. Addition of deemed rent on vacant property was deleted as property constituted stock-in-trade, not house property income. en-us Mon, 30 Oct 2023 00:00:00 +0530 Wed, 08 Nov 2023 09:11:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445443 ITAT Pune held that sale consideration of Rs. 85.79 crore received by assessee on share transfer was not exclusively for shares but also included value for negative covenants, given assessee's indemnity liability up to Rs. 40 crore. The tribunal directed AO to segregate consideration between share transfer (taxable as capital gains) and negative covenants (taxable as business income under section 28(va)). Disallowance under section 14A was upheld as AO correctly applied rule 8D(2)(iii) considering only exempt income yielding securities. Addition of deemed rent on vacant property was deleted as property constituted stock-in-trade, not house property income. Case-Laws Income Tax Mon, 30 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445443