https://www.taxtmi.com/caselaws?id=449430 ITAT Delhi ruled that amounts held in escrow account cannot be taxed as capital gains under sections 45 and 48 when neither received nor likely to be received by the assessee. Following Dinesh Vazirani case, the tribunal held that escrow amounts contingent upon fulfillment of conditions do not form part of full value of consideration received. Such amounts will be taxable in respective years of actual receipt or accrual. Regarding section 14A disallowance, tribunal partially allowed assessee's appeal, directing AO to apply statutory formula under Rule 8D while restricting disallowance to 0.5% of average investment value for administrative expenses, as assessee demonstrated own funds exceeded dividend-yielding investments. en-us Thu, 08 Feb 2024 00:00:00 +0530 Sat, 10 Feb 2024 10:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449430 ITAT Delhi ruled that amounts held in escrow account cannot be taxed as capital gains under sections 45 and 48 when neither received nor likely to be received by the assessee. Following Dinesh Vazirani case, the tribunal held that escrow amounts contingent upon fulfillment of conditions do not form part of full value of consideration received. Such amounts will be taxable in respective years of actual receipt or accrual. Regarding section 14A disallowance, tribunal partially allowed assessee's appeal, directing AO to apply statutory formula under Rule 8D while restricting disallowance to 0.5% of average investment value for administrative expenses, as assessee demonstrated own funds exceeded dividend-yielding investments. Case-Laws Income Tax Thu, 08 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449430