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 April 2024 Year 2024 This

Addition u/s 14A r.w.r.8D - AO mandation to record ...

Income Tax

April 10, 2024

Addition u/s 14A r.w.r.8D - AO mandation to record dis-satisfaction with the correctness of the Assessee's claim regarding expenditure related to exempt income - The Assessee contested the disallowance, arguing that the Assessing Officer did not provide valid reasons for rejecting its explanation. The High Court emphasized the necessity for the AO to record dissatisfaction with the Assessee's claim regarding expenditure related to exempt income and provide cogent reasons for such dissatisfaction. Upon analysis of the AO's assessment order, the Court found deficiencies in the recording of dissatisfaction, indicating a lack of proper application of mind. Consequently, the High Court validated the decision of the ITAT, affirming that the AO failed to adequately justify the disallowance made by the Assessee.

View Source

 


 

You may also like:

  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. 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...

  3. Disallowance u/s. 14A - recording of satisfaction - AO before invoking Rule 8D has issued SCN to the assessee. The AO after considering the reply of assessee negated the...

  4. Disallowance u/s 14A - Mandation of recording satisfaction - suo motu disallowance made by assessee - where suo motu disallowance has been made, the Assessing Officer is...

  5. Disallowance u/s 14A r.w.r. 8D in rectification proceedings u/s 154 - Mandation of recording satisfaction - Recording of satisfaction by the Assessing Officer under Rule...

  6. 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

  7. 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...

  8. Disallowance u/s 14A r.w.r. 8D - suo moto disallowance by assessee - the legal grounds as to applicability of Rule 8D as raised by the Revenue fails since the assessee,...

  9. Assessment u/s 14A r.w.r. 8D - the disallowance under Rule 8D of the IT Rules read with Section 14A of the Act can never exceed the exempted income earned by the...

  10. Disallowance u/s 14A r.w.r. 8D - failure to record satisfaction - as there is a clear lapse on the part of the lower authorities in validly assuming jurisdiction for...

 

Quick Updates:Latest Updates