“Section 2(24)(2a)”
The decision most relied on for Section 2(24)(2a) is CIT v. HDFC Bank (104 Taxmann.com 97), cited in 22 judgments on BharatTax.
Leading authorities on Section 2(24)(2a)
Disallowance under Section 14A is not warranted merely because an assessee has sufficient interest-free funds to make investments that yield exempt income. No disallowance is called for if no expenditure is found to have been incurred for earning exempt income.
An assessment order directing the initiation of penalty proceedings under section 271(1)(c) is deemed to constitute the Assessing Officer's satisfaction for initiating penalty proceedings under section 271(1B). This applies even after amendments to the law.
A penalty under section 271(1)(c) cannot be levied if the assessee made a bona fide mistake of accounting and rectified it by passing necessary rectification entries in a subsequent year, as no mens rea can be inferred.
When imposing a penalty under section 271(1)(c), the Assessing Officer must specify whether the penalty is for furnishing inaccurate particulars or concealment of income, not just initiate the penalty proceedings without a specific charge.