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ITAT dismissed the appeal, upholding the disallowance under section 14A read with Rule 8D. The Tribunal found the AO validly computed disallowance under Rule 8D(2)(ii) on investments alone, notwithstanding absence of a proportional interest disallowance, and rejected the assessee's challenge to the AO's application of mind and alleged failure to record satisfaction. The Tribunal further held that, post-amendment, the assessee was obliged to compute suo moto disallowance even if no exempt income arose, which it failed to do. No infirmity was found in the CIT(A)'s order; the AO's computation under Rule 8D was affirmed and the assessee's appeal dismissed.
ITAT dismissed the appeal, upholding the disallowance under section 14A read with Rule 8D. The Tribunal found the AO validly computed disallowance under Rule 8D(2)(ii) on investments alone, notwithstanding absence of a proportional interest disallowance, and rejected the assessee's challenge to the AO's application of mind and alleged failure to record satisfaction. The Tribunal further held that, post-amendment, the assessee was obliged to compute suo moto disallowance even if no exempt income arose, which it failed to do. No infirmity was found in the CIT(A)'s order; the AO's computation under Rule 8D was affirmed and the assessee's appeal dismissed.
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