Home Highlights February 2019 Year 2019 This

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1. Source of funds for investment made in mutual funds - when the partnership firm and its partners are seen holistically and in a combined manner with costs towards...

2. Disallowance of expenditure u/s 14A read with rule 8D - proportionate disallowance of interest - common pool of funds - if we apply the ratio laid down in the various...

3. Disallowance u/s 14A - Exempted income - proportionate disallowance of interest paid by the banks for investments made in tax free bonds/ securities which yield tax free...

4. Addition u/s 14A r.w.r. 8D regarding interest expenses - mixed funds used for investments - the condition precedent of recording the requisite satisfaction which is a...

5. Claim of interest expenditure - Nexus between investments and borrowed funds - A clear and direct nexus has to be established between the loan funds and the investments...

6. Disallowance u/s.14A in respect of strategic investments made by the assessee - In any case, the undisputed fact is that the borrowed funds has been utilized by the...

7. Disallowance u/s 14A r.w.r. 8D - Addition of interest expenditure - The ITAT found substantial merit in the alternative contention of learned counsel for the assessee...

8. Disallowance u/s 14A - since the shareholders funds are far in excess of the investments, it can be presumed that investments are out of interest free shareholders funds...

9. Disallowance u/s 14A r.w.r. 8D - as argued CIT(A), instead of adopting the average value of investment of which income is not part of the total income i.e., the value of...

10. Disallowance u/s 14A r.w.r. 8D - in the case of mutual funds, administrative and managerial expenses are factored in the investments itself - the explanation offered by...

11. Allowable deduction of interest paid on the borrowings - Section 14A and Section 36(1)(iii) - Exempted dividend income - Based on the discussions and findings, the court...

12. Disallowance u/s 14A - Disallowing interest expense - Neither the assessee furnished the working of disallowances under section 14A, nor the lower authority made the...

13. Disallowance u/s 14A - no dividend income has been received during the year under assessment nor it has borrowed any funds to invest in the share to earn the dividend...

14. Disallowance of proportionate interest u/s 36 (1) (iii) - when assessee had sufficient funds, why should it depend on borrowed funds. In any case, if at a given point of...

15. Interest incurred claimed as a deduction u/s. 57(iii) out of interest earned from mutual funds - In our opinion, unless funds are borrowed for making deposit to earn...