AO’s Failure in Recording Dissatisfaction Invalidates Section 14A Disallowance

Krishnamurthy Thiagarajan Vs ACIT (ITAT Mumbai)

The case of Krishnamurthy Thiagarajan vs ACIT, heard at ITAT Mumbai, revolves around disputes over additions/disallowances concerning management fee payments and disallowance under Section 14A of the Income Tax Act, 1961. The appeal challenges the order of the Commissioner of Income Tax(Appeals)-12, Mumbai, for the Assessment Year 2008-09.

Detailed Analysis:

1. Management Fee Disallowance:

• The appellant earned short-term capital gains and paid a management fee to M/s. BNP Pa

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