https://www.taxtmi.com/caselaws?id=763585 ITAT Ahmedabad upheld AO's disallowance of Rs. 1,56,10,238 under Section 14A following Rule 8D(2) provisions. The tribunal dismissed assessee's appeal regarding delayed PF contributions, citing SC precedent in Checkmate Services case distinguishing employer and employee contributions. However, ITAT ruled favorably on Section 40(a)(i) disallowance, finding no TDS liability for commission payments to non-resident agents without permanent establishment in India. The tribunal also allowed assessee's appeal on Section 36(1)(iii) disallowance for CWIP, noting sufficient own funds exceeded CWIP value by 14 times, making notional interest calculation legally unsustainable. en-us Thu, 19 Dec 2024 00:00:00 +0530 Sun, 22 Dec 2024 08:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763585 ITAT Ahmedabad upheld AO's disallowance of Rs. 1,56,10,238 under Section 14A following Rule 8D(2) provisions. The tribunal dismissed assessee's appeal regarding delayed PF contributions, citing SC precedent in Checkmate Services case distinguishing employer and employee contributions. However, ITAT ruled favorably on Section 40(a)(i) disallowance, finding no TDS liability for commission payments to non-resident agents without permanent establishment in India. The tribunal also allowed assessee's appeal on Section 36(1)(iii) disallowance for CWIP, noting sufficient own funds exceeded CWIP value by 14 times, making notional interest calculation legally unsustainable. Case-Laws Income Tax Thu, 19 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763585