https://www.taxtmi.com/caselaws?id=211180 ITAT (Delhi) allowed the appeal, holding that disallowance under s.14A read with Rule 8D cannot be mechanically made where the assessee contends no expenditure was incurred in relation to exempt income. The Tribunal found the AO and lower authority failed to examine or rebut the assessee's factual claim before computing disallowance; a presumption of expenditure is impermissible. Since the requisite satisfaction and fact-finding under s.14A(1) were not recorded, the disallowance was unsustainable and set aside. en-us Fri, 06 Jan 2012 00:00:00 +0530 Tue, 19 Aug 2025 11:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=211180 ITAT (Delhi) allowed the appeal, holding that disallowance under s.14A read with Rule 8D cannot be mechanically made where the assessee contends no expenditure was incurred in relation to exempt income. The Tribunal found the AO and lower authority failed to examine or rebut the assessee's factual claim before computing disallowance; a presumption of expenditure is impermissible. Since the requisite satisfaction and fact-finding under s.14A(1) were not recorded, the disallowance was unsustainable and set aside. Case-Laws Income Tax Fri, 06 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=211180