The Income Tax Appellate Tribunal (ITAT) has adjudicated on ...

ITAT Remands Tax Deduction Cases for Further Review on Sections 80IA(4), 14A, and 35D; Ensures Natural Justice.

October 11, 2024

Case Laws Income Tax AT

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 ITAT found the Commissioner of Income Tax (Appeals) [CIT(A)]'s observations inadequate to determine the assessee's eligibility as a developer. Hence, the matter was remanded to the CIT(A) for fresh adjudication after examining relevant evidence and providing an opportunity of being heard. Concerning Section 14A disallowance, the ITAT held that no disallowance u/r 8D(2)(b) was warranted as the assessee had sufficient interest-free funds. However, the disallowance u/r 8D(2)(c) was upheld, subject to the CIT(A)'s fresh adjudication on its impact on Section 80IA(4) deduction. Regarding Section 35D disallowance, the ITAT upheld the CIT(A)'s order in part and remanded the matter for fresh adjudication after considering the assessee's evidence and following the principles of natural justice.

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The Income Tax Appellate Tribunal (ITAT) has adjudicated on ...

ITAT Remands Tax Deduction Cases for Further Review on Sections 80IA(4), 14A, and 35D; Ensures Natural Justice.

October 11, 2024

Case Laws Income Tax AT

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