Topic

ITAT Agra Judgment

2 articlesLatest May 2026
Section 14A Disallowance | AO Must Record Objective Satisfaction Before Applying Rule 8D: ITAT Agra Bench
|Income Tax Appellate Tribunal

Section 14A Disallowance | AO Must Record Objective Satisfaction Before Applying Rule 8D: ITAT Agra Bench

ITAT Agra rules that the Assessing Officer must record objective dissatisfaction under Section 14A(2) of the Income Tax Act before invoking Rule 8D for disallowing expenses related to exempt income like dividends. The Tribunal emphasized that mechanical application of Rule 8D without identifying expenditure relatable to exempt income is invalid, reinforcing procedural safeguards for taxpayers.

Section 148 Income Tax Act | Reassessment Notices Issued Beyond TOLA Limitation Period Void: ITAT Agra Quashes Rs. 23 Crore Additions
Case Law Analysis
|Income Tax Appellate Tribunal

Section 148 Income Tax Act | Reassessment Notices Issued Beyond TOLA Limitation Period Void: ITAT Agra Quashes Rs. 23 Crore Additions

ITAT Agra rules reassessment notices under Section 148 of the Income Tax Act issued after 30.06.2021 are time-barred under the Taxation and Other Laws Act (TOLA), invalidating additions exceeding Rs. 23 crore. The judgment reinforces strict adherence to limitation periods, impacting taxpayers facing delayed reassessment proceedings.