https://www.taxtmi.com/caselaws?id=236723 ITAT Kolkata allowed the assessee's challenge to s.14A disallowance under r.8D, upholding the CIT's partial relief and following prior authority. The AO must record a reasoned satisfaction before invoking s.14A(2)/(3). Only investments that actually yield exempt income are relevant for computing disallowance under r.8D, and interest directly attributable to specific business loans is excluded from r.8D(2)(ii). Because the assessee's bank loans were for business purposes with no proof of diversion to exempt-earning investments, the disallowance under s.14A/r.8D was not sustained. en-us Wed, 19 Jun 2013 00:00:00 +0530 Thu, 25 Sep 2025 17:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236723 ITAT Kolkata allowed the assessee's challenge to s.14A disallowance under r.8D, upholding the CIT's partial relief and following prior authority. The AO must record a reasoned satisfaction before invoking s.14A(2)/(3). Only investments that actually yield exempt income are relevant for computing disallowance under r.8D, and interest directly attributable to specific business loans is excluded from r.8D(2)(ii). Because the assessee's bank loans were for business purposes with no proof of diversion to exempt-earning investments, the disallowance under s.14A/r.8D was not sustained. Case-Laws Income Tax Wed, 19 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236723