Necessity of establishing nexus between expenditure incurred and ...

Nexus between expenses & exempt income u/s 14A crucial. Rule 8D application requires due diligence. Bogus capital loss addition rightly deleted. Speculation loss treatment appropriate.

July 5, 2024

Case Laws Income Tax AT

Necessity of establishing nexus between expenditure incurred and earning of exempt income u/s 14A read with Rule 8D. Mechanical application of Rule 8D without recording requisite satisfaction violates procedural requirement u/s 14A(2). Disallowance restricted to exempt income earned. Deletion of addition for bogus long-term capital loss upheld due to lack of substantial evidence and failure to provide opportunity for cross-verification. Addition of speculation loss claimed under "income from other sources" dismissed as it represented depreciation related to speculation business, properly accounted for with nullifying effect on returned income. Procedural lapses by Assessing Officer noted.

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Necessity of establishing nexus between expenditure incurred and ...

Nexus between expenses & exempt income u/s 14A crucial. Rule 8D application requires due diligence. Bogus capital loss addition rightly deleted. Speculation loss treatment appropriate.

July 5, 2024

Case Laws Income Tax AT

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