Home Highlights February 2019 Year 2019 This

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1. Source of funds for investment made in mutual funds - when the partnership firm and its partners are seen holistically and in a combined manner with costs towards...

2. Disallowance of expenditure u/s 14A read with rule 8D - proportionate disallowance of interest - common pool of funds - if we apply the ratio laid down in the various...

3. Disallowance u/s 14A read with Rule 8D - Assessing Officer did not record objective satisfaction for not accepting suo moto disallowance made by assessee. ITAT directed...

4. Disallowance u/s 14A - Exempted income - proportionate disallowance of interest paid by the banks for investments made in tax free bonds/ securities which yield tax free...

5. 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...

6. Claim of interest expenditure - Nexus between investments and borrowed funds - A clear and direct nexus has to be established between the loan funds and the investments...

7. Disallowance u/s.14A in respect of strategic investments made by the assessee - In any case, the undisputed fact is that the borrowed funds has been utilized by the...

8. Disallowance u/s 14A read with Rule 8D - The assessing officer's reliance on CBDT Circular No. 5 of 2014 to make disallowance u/s 14A is legally untenable and liable to...

9. Disallowance of interest difference between the rate paid on borrowed capital and the rate advanced to a wholly owned subsidiary is not warranted. The Supreme Court in S....

10. Disallowance u/s 14A r.w.r. 8D - Addition of interest expenditure - The ITAT found substantial merit in the alternative contention of learned counsel for the assessee...

11. Disallowance u/s 14A - since the shareholders funds are far in excess of the investments, it can be presumed that investments are out of interest free shareholders funds...

12. Allowable deduction of interest paid on the borrowings - Section 14A and Section 36(1)(iii) - Exempted dividend income - Based on the discussions and findings, the court...

13. The ITAT Delhi addressed the issue of accrual of income and chargeability of income-tax on surcharge income offered by the assessee on a receipt basis. The assessee...

14. Disallowance u/s 14A r.w.r. 8D - as argued CIT(A), instead of adopting the average value of investment of which income is not part of the total income i.e., the value of...

15. Disallowance u/s 14A r.w.r. 8D - in the case of mutual funds, administrative and managerial expenses are factored in the investments itself - the explanation offered by...