https://www.taxtmi.com/caselaws?id=752585 The ITAT Kolkata ruled in favor of the assessee on multiple grounds. The tribunal allowed set-off of losses against income under section 68 read with section 115BBE for assessment years 2011-12 and 2015-16, following Kerala HC precedent and CBDT circular. The addition under section 40A(2)(b) for excess payment to related parties was deleted after the assessee demonstrated comparable transactions with unrelated parties at higher rates. Disallowance under section 14A was removed as no exempt income was earned during the year, following Delhi HC precedent. Addition for outstanding advances was deleted since amounts were returned within the year and properly documented through banking channels. en-us Mon, 01 Jan 2024 00:00:00 +0530 Tue, 14 May 2024 06:53:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752585 The ITAT Kolkata ruled in favor of the assessee on multiple grounds. The tribunal allowed set-off of losses against income under section 68 read with section 115BBE for assessment years 2011-12 and 2015-16, following Kerala HC precedent and CBDT circular. The addition under section 40A(2)(b) for excess payment to related parties was deleted after the assessee demonstrated comparable transactions with unrelated parties at higher rates. Disallowance under section 14A was removed as no exempt income was earned during the year, following Delhi HC precedent. Addition for outstanding advances was deleted since amounts were returned within the year and properly documented through banking channels. Case-Laws Income Tax Mon, 01 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752585