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ITAT held that Rule 8D could not be invoked for the exempt-dividend disallowance because the assessee had given a specific expenditure working and the Assessing Officer neither found a defect in the accounts nor recorded the objective dissatisfaction required under section 14A(2); the additional disallowance was deleted. The related MAT adjustment also failed, as the deleted section 14A disallowance could not be carried into book-profit computation and Rule 8D could not be mechanically imported into clause (f) of Explanation 1 to section 115JB. On the Form 26AS mismatch, the matter was remanded for limited verification of the reconciliation and supporting records. Maintenance dredging of the existing jetty area was allowed as revenue expenditure because it preserved operational depth without creating a new asset or capital advantage.
ITAT held that Rule 8D could not be invoked for the exempt-dividend disallowance because the assessee had given a specific expenditure working and the Assessing Officer neither found a defect in the accounts nor recorded the objective dissatisfaction required under section 14A(2); the additional disallowance was deleted. The related MAT adjustment also failed, as the deleted section 14A disallowance could not be carried into book-profit computation and Rule 8D could not be mechanically imported into clause (f) of Explanation 1 to section 115JB. On the Form 26AS mismatch, the matter was remanded for limited verification of the reconciliation and supporting records. Maintenance dredging of the existing jetty area was allowed as revenue expenditure because it preserved operational depth without creating a new asset or capital advantage.
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