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Income Tax - Highlights / Catch Notes

Home Highlights March 2016 Year 2016 This

Disallowance u/s 14A - without establishing any nexus between ...

Income Tax

March 5, 2016

Disallowance u/s 14A - without establishing any nexus between the expenditure incurred and investment, Rule 8D cannot be invoked - AT

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  1. Addition u/s 14A read with rule 8D - categorical finding and satisfaction of the A.O. that expenditure has been incurred to earn the exempt income - Disallowance upheld

  2. Disallowance u/s 14A - There is direct and proximate nexus between the exempted income, which the investments shall genearate and the expenditures directly or indirectly...

  3. Disallowance u/s 14A r.w.r. 8D - sourcing of investment from borrowed funds or own funds - investment is taken as stock-in-trade - ex-parte order - additions confirmed.

  4. Disallowance u/s 14A read with Rule 8D - In any case, as per section 14A(3) whether or not the assessee has incurred any expenditure for earning exempt income, a part of...

  5. Disallowance u/s 14A by invoking Rule-8D - disallowance cannot be made in case where the assessee is having sufficient interest free funds - AT

  6. Disallowance u/s 14A r.w.r. 8D - since AO has mechanically applied the provisions of Rule 8D while making the aforesaid disallowance without establishing any nexus of...

  7. 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...

  8. Estimation of expenditure incurred in earning the exempt income -as the assesee’s explanation is not satisfactory, therefore, provisions contained in 14A are applicable...

  9. Disallowance u/s 14A - The expenditure incurred exclusively for business activity cannot be included in such attributable expenses for the purpose of disallowance u/s.14A - AT

  10. Disallowance u/s 14A - expenses towards exempted income - AO could not have straightaway resorted to Rule 8D(2)(iii) of the Rules in order to compute the disallowance u/s 14A - AT

 

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