M/s SLK Software Pvt. Ltd. vs. The Asst. Commissioner of Income Tax
Case No: ITA Nos. 932 & 933/Bang/2023
Court: Income Tax Appellate Tribunal, ‘C’ Bench, Bangalore
Date: 1/31/2025
Parties Involved
appellantM/s SLK Software Pvt. Ltd.
respondentThe Asst. Commissioner of Income Tax
Facts Summary
The assessee, M/s SLK Software Pvt. Ltd., is a private limited company engaged in providing technological solutions and services. During the assessment years 2017-18 and 2018-19, the assessee earned exempt income in the form of dividends amounting to ₹ 1,15,60,948. The assessee made a suo motu disallowance of ₹ 8,04,994 under section 14A of the Act. The Assessing Officer (AO) invoked Rule 8D of the Income Tax Rules to compute additional disallowance, presuming that the assessee utilized interest…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the AO erred in invoking Rule 8D without recording dissatisfaction regarding the suo motu disallowance made by the assessee.
- 2. Whether the CIT(A) erred in confirming the addition made by the AO on account of non-deduction of TDS on payments made to overseas parties.
Precedents Relied Upon
4 precedents cited in this judgement.