https://www.taxtmi.com/caselaws?id=446101 ITAT Surat dismissed Revenue's appeal on two grounds. First, regarding disallowance under section 14A, the Tribunal upheld CIT(A)'s deletion of addition, finding assessee had sufficient own funds (436 crores) compared to investments generating exempt income (8.05 crores), establishing no borrowed funds were used. Second, concerning salary disallowance under section 40A(2)(b) to relatives lacking educational qualifications, the Tribunal ruled that diamond business requires experience-based skills rather than formal education, payments were made through proper channels with TDS, and recipients were taxed at 30% rate showing no tax avoidance motive. The Tribunal emphasized business confidentiality requirements and rejected AO's interference in Board decisions regarding reliable personnel and compensation. en-us Thu, 26 Oct 2023 00:00:00 +0530 Fri, 24 Nov 2023 14:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446101 ITAT Surat dismissed Revenue's appeal on two grounds. First, regarding disallowance under section 14A, the Tribunal upheld CIT(A)'s deletion of addition, finding assessee had sufficient own funds (436 crores) compared to investments generating exempt income (8.05 crores), establishing no borrowed funds were used. Second, concerning salary disallowance under section 40A(2)(b) to relatives lacking educational qualifications, the Tribunal ruled that diamond business requires experience-based skills rather than formal education, payments were made through proper channels with TDS, and recipients were taxed at 30% rate showing no tax avoidance motive. The Tribunal emphasized business confidentiality requirements and rejected AO's interference in Board decisions regarding reliable personnel and compensation. Case-Laws Income Tax Thu, 26 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446101