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Disallowance u/s 14A read with Rule 8D - Suo moto disallowance ...


Assessee's disallowance restricted; paintings expensed; currency fire loss remanded for fresh adjudication.

Case Laws     Income Tax

August 16, 2024

Disallowance u/s 14A read with Rule 8D - Suo moto disallowance by assessee upheld, disallowance restricted to Rs. 2,00,000 for the year, following HT Media Ltd. decision. Disallowance u/s 14A while computing book profits u/s 115JB - Actual expenditure of Rs. 2,00,000 disallowed, as per Vireet Investments P Ltd. decision. Expenditure on paintings allowed as revenue expenditure, following Wipro Ltd. decision, being for aesthetic purpose and better environment. Disallowance on account of currency burnt in fire - Issue restored to Assessing Officer for fresh adjudication considering additional evidence of advance received from scrap dealer, with direction to allow loss if advance burnt, and avoid double taxation in subsequent year if disallowed.

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