S. 14A : Disallowance of expenditure-Exempt income-Share application money pending allotment at year end-Not to be treated as investment yielding exempt income. [R. 8D]
Kumar Urban Development Ltd. v. ITO (2020) 84 ITR 17 (SN) (Pune) (Trib.)S. 14A : Disallowance of expenditure-Exempt income-Share application money pending allotment at year end-Not to be treated as investment yielding exempt income. [R. 8D]
Kumar Urban Development Ltd. v. ITO (2020) 84 ITR 17 (SN) (Pune) (Trib.)S. 14A : Disallowance of expenditure-Exempt income-Interest-Disallowance of interest on net interest-Higher interest income-No disallowance can be made-Sufficient interest free funds-Presumption that investment and advances were made out of such funds-No interest to be disallowed. [S. 36(1)(iii), R. 8D]
Dy.CIT v. Priyal International P. Ltd. (2020) 84 ITR 50 (SN) (Ahd.) (Trib.)S. 14A : Disallowance of expenditure-Exempt income-Interest-Own funds more than the investment-Presumption is investment is from own funds-No disallowance of interest can be made-Erroneous disallowance shown in the return-Indirect expenses-Only investments actually yielding exempt income to be considered for working out disallowance-Assessment cannot be based on consent or acceptance of assessee either in return or during course of assessment or Appellate Proceedings. [S. 143(3), R. 8D(2)(iii), Art. 265]
Dy.CIT v. Godrej Properties Ltd. (2020) 84 ITR 13 (SN) (Mum.) (Trib.)S. 14A : Disallowance of expenditure-Exempt income-Not earning any dividend income during year and not claiming exemption-Disallowance cannot be made. [R. 8D]
Assetz Infrastructure Pvt. Ltd. v. Dy.CIT (2020) 84 ITR 59 (SN) (Bang.)(Trib.)S. 13 : Denial of exemption-Trust or institution-Investment restrictions-Benefit to Trustees-Interest rate of 10% was paid to trustees on unsecured loan from Trustees-Exemption cannot be denied. [S. 11, 12A, 80G]
Shaheed Kartar Singh Saraba Charitable Trust (Regd.) v. Dy.CIT(E) (2020) 84 ITR 27 (SN) (Chd.)(Trib.)S. 11 : Property held for charitable purposes-Corpus donations-Capital receipts-Not taxable-Direction of the CIT(A) is held to be valid. [S. 2(24(iia), 12AA]
ACIT v. A. Shama Rao Foundation (2020) 84 ITR 49 (SN) (Bang.) (Trib.)S. 10AA : Special economic zones-Transfer pricing adjustment-Deduction allowable. [S. 92C]
Eygbs (India) LLP v. Dy.CIT (2020) 84 ITR 48 (SN) (Bang.)(Trib.)S. 10(34) : Dividend-Domestic companies-Tax on distribution of profits-Venture Capital Company-Entitle to [S. 10(38), 115O]
Japan International Co-Operation Agency v. ACIT(IT) (2020) 84 ITR 25 (SN) (Delhi)(Trib.)S. 2(22)(e) : Dividend-Deemed dividend-Accumulated profits-Loans from subsidiary-Assessable as deemed dividend.
Assetz Infrastructure Pvt. Ltd. v. Dy.CIT (2020) 84 ITR 59 (SN) (Bang.)(Trib.)S. 271(1)(c) : Penalty-Concealment-Show-cause Notice and penalty order not specifying the charge-Levy of penalty is held to be not valid. [S. 274]
Sequel Alloys and Wires Pvt. Ltd. v. Dy. CIT (2020) 83 ITR 190 (Delhi)(Trib.)