https://www.taxtmi.com/caselaws?id=253863 ITAT, Mumbai upheld disallowance under s.14A(1) against an NBFC. The tribunal found the assessee's apportionment method had rationale and partial validation but was arbitrary in places and de hors accounts; proximate causation between expenditure and tax-exempt income was satisfied and expenses allowable under other sections remain disallowable under the standalone code of s.14A. As the assessee failed to discharge the initial factual onus, the disallowance could not be faulted for alleged procedural non-compliance. The s.14A(1) disallowance was therefore sustained. en-us Fri, 01 Aug 2014 00:00:00 +0530 Fri, 31 Oct 2025 16:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253863 ITAT, Mumbai upheld disallowance under s.14A(1) against an NBFC. The tribunal found the assessee's apportionment method had rationale and partial validation but was arbitrary in places and de hors accounts; proximate causation between expenditure and tax-exempt income was satisfied and expenses allowable under other sections remain disallowable under the standalone code of s.14A. As the assessee failed to discharge the initial factual onus, the disallowance could not be faulted for alleged procedural non-compliance. The s.14A(1) disallowance was therefore sustained. Case-Laws Income Tax Fri, 01 Aug 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253863