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Section 14A/Mat Disallowances: Section 14A Disallowance: A Comprehensive Assessee Defense Strategy Across DRP, CIT(A), and ITAT
1. INTRODUCTION: THE ASSESSEE’S STRATEGIC LANDSCAPE Understanding the Asymmetry The relationship between the tax department and the assessee is inherently asymmetrical. The D
Department’s Perspective on Section 14A and MAT – The Revenue’s Case, Arguments & Strategic Position
1. INTRODUCTION: UNDERSTANDING THE REVENUE’S MINDSET The Department is Not Arbitrary A common misconception: The tax department is merely aggressive, trying to extract maximu
Explanation 1 to Section 115JB – A Clause-By-Clause Analysis Of Book Profit Adjustments
1. INTRODUCTION: THE ARCHITECTURE OF BOOK PROFIT What is Explanation 1? Explanation 1 to Section 115JB(2) is the rulebook for computing book profit. It specifies, with surgical pre
Minimum Alternate Tax (MAT) Demystified – Book Profit vs. Taxable Income Explained
1. INTRODUCTION: THE TWIN TAX PROBLEM The Scenario That Started It All Imagine it’s the year 1997. You’re a wealthy Indian businessman running a successful manufacturin
Section 14A in MAT (Section 115JB): Can Rule 8d Disallowances Inflate Book Profits?
1. The Core Contradiction: Section 14A vs Section 115JB MAT The Core Contradiction Imagine this scenario: Company ABC Ltd. for AY 2023-24: Under Section 14A (Normal Computat
