https://www.taxtmi.com/caselaws?id=755060 The ITAT Ahmedabad ruled in favor of the assessee on multiple grounds. Regarding Section 14A disallowance, the tribunal held that the AO mechanically applied Rule 8D without establishing nexus between expenditure and exempt income or recording requisite satisfaction, violating procedural requirements. The CIT(A)'s decision to restrict disallowance to actual exempt income earned was upheld. For bogus LTCL claims, the tribunal deleted the addition as the AO failed to provide substantial evidence and relied solely on Investigation Wing data without independent verification or giving cross-examination opportunity. The speculation loss addition was also dismissed as the amount represented depreciation with nullifying effect on returned income. en-us Tue, 02 Jul 2024 00:00:00 +0530 Thu, 04 Jul 2024 12:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755060 The ITAT Ahmedabad ruled in favor of the assessee on multiple grounds. Regarding Section 14A disallowance, the tribunal held that the AO mechanically applied Rule 8D without establishing nexus between expenditure and exempt income or recording requisite satisfaction, violating procedural requirements. The CIT(A)'s decision to restrict disallowance to actual exempt income earned was upheld. For bogus LTCL claims, the tribunal deleted the addition as the AO failed to provide substantial evidence and relied solely on Investigation Wing data without independent verification or giving cross-examination opportunity. The speculation loss addition was also dismissed as the amount represented depreciation with nullifying effect on returned income. Case-Laws Income Tax Tue, 02 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755060