<?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>Assessee succeeds: s.14A and r.8D disallowances deleted; r.8D(2)(ii)/(iii) confined, s.36(1)(iii) additions removed; commissions and inter-company advances held allowable</title>
    <link>https://www.taxtmi.com/highlights?id=93732</link>
    <description>The ITAT allowed the appeal of the assessee. Disallowance under s.14A read with r.8D was deleted as assessee&#039;s own funds exceeded investments, permitting presumption investments were from own funds. Payments of commission were held not excessive and allowable. Additions under s.36(1)(iii) in respect of inter-company transactions were deleted as bona fide business dealings, not loans. Suo-moto disallowances made in the return under r.8D(2)(ii) and r.8D(2)(iii) were ordered deleted; r.8D(2)(iii) computations confined to investments yielding exempt income and AO directed to verify calculations. Advances to subsidiary/sister concerns held commercially expedient; AO directed to delete related interest disallowances.</description>
    <language>en-us</language>
    <pubDate>Fri, 31 Oct 2025 08:23:13 +0530</pubDate>
    <lastBuildDate>Fri, 31 Oct 2025 08:23:15 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=861355" rel="self" type="application/rss+xml"/>
    <item>
      <title>Assessee succeeds: s.14A and r.8D disallowances deleted; r.8D(2)(ii)/(iii) confined, s.36(1)(iii) additions removed; commissions and inter-company advances held allowable</title>
      <link>https://www.taxtmi.com/highlights?id=93732</link>
      <description>The ITAT allowed the appeal of the assessee. Disallowance under s.14A read with r.8D was deleted as assessee&#039;s own funds exceeded investments, permitting presumption investments were from own funds. Payments of commission were held not excessive and allowable. Additions under s.36(1)(iii) in respect of inter-company transactions were deleted as bona fide business dealings, not loans. Suo-moto disallowances made in the return under r.8D(2)(ii) and r.8D(2)(iii) were ordered deleted; r.8D(2)(iii) computations confined to investments yielding exempt income and AO directed to verify calculations. Advances to subsidiary/sister concerns held commercially expedient; AO directed to delete related interest disallowances.</description>
      <category>Highlights</category>
      <law>Income Tax</law>
      <pubDate>Fri, 31 Oct 2025 08:23:13 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/highlights?id=93732</guid>
    </item>
  </channel>
</rss>