Disallowance u/s 14A read with Rule 8D - Assessing Officer did ...

Disallowance u/s 14A: AO to accept assessee's suo moto disallowance. Only non-exempt income yielding investments considered. Deduction u/s 80G allowed except for specific Kosh, Fund & CSR contributions.

Case Laws Income Tax

August 10, 2024

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 Assessing Officer to accept suo moto disallowance made u/r 8D(2)(iii) read with Section 14A. Only investments not yielding exempt income should be considered for disallowance u/s 14A read with Rule 8D. Deduction u/s 80G for donations - Deduction allowable for sums paid as donation. Donations to specific Kosh and Fund not allowable u/s 80G(2)(a)(iiihk) and (iiihl). Amounts spent on CSR activities u/s 135 of Companies Act 2013 not allowable as deduction u/s 80G. Disallowance for deduction u/s 80G vis-a-vis CSR restricted to contributions to these Funds under CSR. No error in allowing deduction claimed u/s 80G, except for contributions to these two funds.

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Disallowance u/s 14A read with Rule 8D - Assessing Officer did ...

Disallowance u/s 14A: AO to accept assessee's suo moto disallowance. Only non-exempt income yielding investments considered. Deduction u/s 80G allowed except for specific Kosh, Fund & CSR contributions.

Case Laws Income Tax

August 10, 2024

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