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Income Tax - Highlights / Catch Notes

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Disallowance u/s 14A r.w.r. 8D - since AO has mechanically ...


AO's Mechanical Application of Rule 8D u/s 14A Deemed Unsustainable; Disallowance to be Removed for Income Calculation.

December 21, 2022

Case Laws     Income Tax     AT

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 expenditure claimed by the assessee with that of exempt income earned during the year, such disallowance is not sustainable in law. Accordingly, Ld. AO is directed to delete the additional disallowance while computing income under normal provisions as well as while computing Book profits u/s 115JB. - AT

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