https://www.taxtmi.com/caselaws?id=756214 The Kerala HC dismissed writ petitions challenging reopening of assessments under Section 147 for additions under Section 14A read with Rule 8D. The court held that the assessing officer had valid reasons to believe income escaped assessment when the petitioner claimed interest expenditure on loans used for investment in a company earning exempt income. The court found the original assessments were not in accordance with law as Section 14A and Circular No.5/14 were ignored, constituting valid grounds for reopening rather than mere change of opinion. Rule 8D, effective from 2008, provides methodology for computing disallowed expenditure. The court directed that if reassessment proceedings are complete and petitioner has grievances, statutory appeal remedy should be pursued, with time spent in writ proceedings to be condoned. en-us Thu, 15 Feb 2024 00:00:00 +0530 Mon, 29 Jul 2024 11:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756214 The Kerala HC dismissed writ petitions challenging reopening of assessments under Section 147 for additions under Section 14A read with Rule 8D. The court held that the assessing officer had valid reasons to believe income escaped assessment when the petitioner claimed interest expenditure on loans used for investment in a company earning exempt income. The court found the original assessments were not in accordance with law as Section 14A and Circular No.5/14 were ignored, constituting valid grounds for reopening rather than mere change of opinion. Rule 8D, effective from 2008, provides methodology for computing disallowed expenditure. The court directed that if reassessment proceedings are complete and petitioner has grievances, statutory appeal remedy should be pursued, with time spent in writ proceedings to be condoned. Case-Laws Income Tax Thu, 15 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756214