https://www.taxtmi.com/caselaws?id=263872 Section 14A disallowance of interest under Rule 8D(2)(i) was found unsustainable where the Revenue could not prove a direct nexus between surplus business funds and exempt investments; mere seasonal availability of funds was insufficient. Section 50C was held inapplicable to the computation of written down value of a depreciable block of assets, because it is confined to capital gains computation under sections 45 and 48 and does not alter section 43(6) WDV. For Rule 8D(2)(ii), the interest allocation was required to be recomputed by reference to the full-year interest cost, as the adjustment operated as an internal reallocation under Rule 8D. en-us Wed, 11 Mar 2015 00:00:00 +0530 Sat, 12 Sep 2015 08:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=263872 Section 14A disallowance of interest under Rule 8D(2)(i) was found unsustainable where the Revenue could not prove a direct nexus between surplus business funds and exempt investments; mere seasonal availability of funds was insufficient. Section 50C was held inapplicable to the computation of written down value of a depreciable block of assets, because it is confined to capital gains computation under sections 45 and 48 and does not alter section 43(6) WDV. For Rule 8D(2)(ii), the interest allocation was required to be recomputed by reference to the full-year interest cost, as the adjustment operated as an internal reallocation under Rule 8D. Case-Laws Income Tax Wed, 11 Mar 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=263872