Rule 8D disallowance requires the Assessing Officer to record...

Rule 8D disallowance requires the Assessing Officer to record specific dissatisfaction, after examining the taxpayer's working, before indirect expenditure relating to exempt income can be disallowed; general observations on investments are insufficient. Where own interest-free funds cover exempt-income investments, a presumption applies that those investments were made from such funds, preventing interest disallowance. Eligible captive power undertakings may compute profits on a standalone basis, use regulated industrial tariffs as an internal comparable for captive electricity, and claim investment allowance when capital work-in-progress is installed and commissioned during the year. Corporate advertising, lease equalisation charges and employee stock-option costs may qualify as revenue expenditure. Subsidies linked to technology-upgradation investment are capital receipts, while scheme-based incentives require factual examination.