<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>2024 (12) TMI 108 - ITAT DELHI</title>
    <link>https://www.taxtmi.com/caselaws?id=762528</link>
    <description>Where an assessee has substantial own funds in the form of share capital and reserves, no long-term borrowings, and no fresh investment during the year, a presumption arises that investments yielding exempt income were made from those own funds. On those facts, the basis for disallowance under section 14A read with Rule 8D does not survive, because the funding nexus for invoking the rule is not established. The note states that the disallowance was therefore not sustainable and that the issue was decided in favour of the assessee.</description>
    <language>en-us</language>
    <pubDate>Fri, 29 Nov 2024 00:00:00 +0530</pubDate>
    <lastBuildDate>Mon, 02 Dec 2024 17:59:00 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=780403" rel="self" type="application/rss+xml"/>
    <item>
      <title>2024 (12) TMI 108 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=762528</link>
      <description>Where an assessee has substantial own funds in the form of share capital and reserves, no long-term borrowings, and no fresh investment during the year, a presumption arises that investments yielding exempt income were made from those own funds. On those facts, the basis for disallowance under section 14A read with Rule 8D does not survive, because the funding nexus for invoking the rule is not established. The note states that the disallowance was therefore not sustainable and that the issue was decided in favour of the assessee.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Fri, 29 Nov 2024 00:00:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/caselaws?id=762528</guid>
    </item>
  </channel>
</rss>