Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights August 2015 Year 2015 This

Disallowance u/s 14A(2) r.w.r. 8D(2)(ii) - expenditure will have ...


Section 14A(2) & Rule 8D(2)(ii): Back-to-back transactions impact expense allocation for tax, not from common funds.

August 27, 2015

Case Laws     Income Tax     AT

Disallowance u/s 14A(2) r.w.r. 8D(2)(ii) - expenditure will have to be excluded from the expenses to be allocated under rule 8D(2)(ii) - entire transaction of borrowing and landing is completely a back to back transaction - Just because it is routed through the same bank account, it cannot be presumed that the money is out of the common funds - AT

View Source

 


 

You may also like:

  1. Addition u/s 14A r.w. Rule 8D(2)(iii) - In the present case, wherein the assessee does not offer any disallowance under Rule 8D(2)(ii) in respect of exempt income, then...

  2. Addition u/s 56(2)(vii)(b) - valuation of land purchased by assessee - deemed gift under section 56(2)(vii)(b)(ii) - Assessee submitted that, actual deed could not be...

  3. Disallowance u/s 14A read with Rule 8D - the AO has not computed any disallowance under Rule 8D(2)(i) and Rule 8D(2)(ii) of the Rules and only under Rule 8D(2)(iii) of...

  4. Disallowance u/s 14A read with Rule 8D - The assessing officer's reliance on CBDT Circular No. 5 of 2014 to make disallowance u/s 14A is legally untenable and liable to...

  5. Addition u/s 14A r.w.r. 8D - Addition under special provision u/s 115JB - Minimum Alternate Tax (MAT) - the case revolved around the disallowance made under Section 14A...

  6. Constitutional validity of Section 13(8)(b) read with Section 8(2) of the IGST Act - Supply of intermediary services as intermediary to his overseas customers - Neither...

  7. Research and Development expenses (R&D Expenses) - Allowability of expenses u/s 35(2) - The expenses are not covered u/s 35(2) - The assessee has not claimed the same...

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

  9. The Income Tax Appellate Tribunal (ITAT) has adjudicated on various issues concerning deductions u/ss 80IA(4), 14A, and 35D. Regarding Section 80IA(4) deduction, the...

  10. Applicability of Section 56(2)(x) of the Income Tax Act to the transfer or surrender of tenancy rights. It states that Section 56(2)(x) is a deeming provision akin to...

  11. The ITAT adjudicated multiple tax issues for an insurance company. Key holdings include: (1) dividend income must be offered on gross basis; (2) payments to auto dealers...

  12. This case deals with the disallowance of expenditure u/s 14A of the Income Tax Act, which pertains to expenditure incurred in relation to exempt income. The key points...

  13. CIRP - Preferential Transactions or not - related transaction or not - Transaction within look bak period - such transactions are carried with intent to defraud...

  14. ITAT ruled in favor of the assessee across multiple taxation issues. The tribunal found no merit in the revenue department's contentions regarding management consultancy...

  15. The assessee entered into an agreement for sale and made substantial payment for a property in the assessment year (AY) 2013-14. The Assessing Officer (AO) was not...

 

Quick Updates:Latest Updates