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