https://www.taxtmi.com/caselaws?id=765221 The ITAT Delhi remanded two issues back to the AO. First, regarding disallowance under section 14A read with Rule 8D, the tribunal directed the AO to identify investments generating exempt income and recompute disallowance at 1% on average value of only those investments, following the Vireet Investments precedent. Second, on the additional ground concerning concessional fee income allegedly double-taxed across AY 2018-19 and 2019-20, the tribunal admitted the new claim citing Goetze India SC precedent and directed the AO to verify if the disputed income was already offered for taxation in the previous year to avoid double taxation. Both CIT(A) orders were set aside with specific directions for fresh examination. en-us Wed, 15 Jan 2025 00:00:00 +0530 Tue, 28 Jan 2025 08:24:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765221 The ITAT Delhi remanded two issues back to the AO. First, regarding disallowance under section 14A read with Rule 8D, the tribunal directed the AO to identify investments generating exempt income and recompute disallowance at 1% on average value of only those investments, following the Vireet Investments precedent. Second, on the additional ground concerning concessional fee income allegedly double-taxed across AY 2018-19 and 2019-20, the tribunal admitted the new claim citing Goetze India SC precedent and directed the AO to verify if the disputed income was already offered for taxation in the previous year to avoid double taxation. Both CIT(A) orders were set aside with specific directions for fresh examination. Case-Laws Income Tax Wed, 15 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765221