https://www.taxtmi.com/caselaws?id=217069 ITAT Kolkata upheld the application of Section 14A read with Rule 8D for AY 08-09, ruling that when the assessee does not offer any disallowance under Section 14A, the AO can invoke these provisions without recording satisfaction about the incorrectness of the claim. The Tribunal rejected the assessee's challenge on this ground. Regarding the computation under Rule 8D(2)(ii), the ITAT noted the inconsistency in the allocation of interest expenses and relied on the Bombay HC decision in Godrej Boyce, which excludes interest directly attributable to both tax-exempt and taxable income from the common interest expense pool. Consequently, the AO's approach was rejected in principle, but the matter was remitted for factual verification consistent with the correct formula application. en-us Fri, 21 Sep 2012 00:00:00 +0530 Wed, 13 Aug 2025 12:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=217069 ITAT Kolkata upheld the application of Section 14A read with Rule 8D for AY 08-09, ruling that when the assessee does not offer any disallowance under Section 14A, the AO can invoke these provisions without recording satisfaction about the incorrectness of the claim. The Tribunal rejected the assessee's challenge on this ground. Regarding the computation under Rule 8D(2)(ii), the ITAT noted the inconsistency in the allocation of interest expenses and relied on the Bombay HC decision in Godrej Boyce, which excludes interest directly attributable to both tax-exempt and taxable income from the common interest expense pool. Consequently, the AO's approach was rejected in principle, but the matter was remitted for factual verification consistent with the correct formula application. Case-Laws Income Tax Fri, 21 Sep 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=217069