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

Case Laws 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

← Previous Next →

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

Case Laws Income Tax

April 10, 2024

You may also like:

Disallowance u/s. 14A r.w. Rule 8D - Mandation of recording satisfaction- We find that the AO had after exhaustively dealing with the contention advanced by the assessee...

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...

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...

Disallowance u/s 14A r.w.r. 8D - no proper recording of satisfaction by the AO for rejecting the suomoto disallowance made by the Assessee - The Tribunal found that in...

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...

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...

Disallowance u/s 14A - it was incumbent for Ld. AO to record a satisfaction as to why the disallowance offered by the assessee was not sufficient and this said...

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...

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...

Disallowance u/s 14A r.w.s 8D - AO did not in any manner reject explanation of the assessee but merely proceeded to make disallowance bu/s 14A - satisfaction of the AO...

Disallowance u/s 14A - the A.O had after necessary deliberations observed that with reference to the accounts of the assessee, he was not satisfied with the correctness...

Penalty u/s 271(1)(c) - non recording of satisfaction - When satisfaction for initiation of penalty proceedings u/s 271(1)(c) of IT Act is recorded by the AO in...

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...

Disallowance u/s 14A - necessity of recording satisfaction - Dissatisfaction of the AO is expressly recorded in the assessment order. The said dissatisfaction has been...

The assessment u/s 153C mandates the recording of satisfaction by the Assessing Officer (AO) upon discovery of material likely to "have a bearing on the determination of...

Quick Updates: