https://www.taxtmi.com/caselaws?id=253711 Rule 8D under section 14A could not be invoked mechanically where the assessee claimed that no borrowed funds or exempt-income expenditure was used and the Assessing Officer failed to record dissatisfaction with that claim on the basis of the accounts; the disallowance was therefore deleted. Professional fees and contract payments also could not be disallowed under section 40(a)(ia) merely because the tax deducted at source was deposited in April 2008 against earlier invoices, since deposit within the period recognised for the relevant assessment year prevented disallowance; those additions were likewise deleted. The assessee succeeded on both substantive issues. en-us Wed, 12 Nov 2014 00:00:00 +0530 Tue, 02 Dec 2014 09:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253711 Rule 8D under section 14A could not be invoked mechanically where the assessee claimed that no borrowed funds or exempt-income expenditure was used and the Assessing Officer failed to record dissatisfaction with that claim on the basis of the accounts; the disallowance was therefore deleted. Professional fees and contract payments also could not be disallowed under section 40(a)(ia) merely because the tax deducted at source was deposited in April 2008 against earlier invoices, since deposit within the period recognised for the relevant assessment year prevented disallowance; those additions were likewise deleted. The assessee succeeded on both substantive issues. Case-Laws Income Tax Wed, 12 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253711