https://www.taxtmi.com/caselaws?id=271013 Section 14A read with Rule 8D could not sustain the major disallowance where the assessee had substantial own funds, the investment was carried forward from earlier years, and the Assessing Officer had applied Rule 8D without recording the required satisfaction; only a small management-expense element was retained. Interest on hire purchase loans classified as NPAs in the hands of an NBFC was not taxable on accrual basis because RBI prudential norms required income recognition only on receipt basis, and mere book entries or borrower confirmations did not create real income. A difference in opening hire purchase loan balance could not be taxed in the year under appeal unless the Revenue showed that the alleged unexplained amount arose in that year. en-us Fri, 04 Dec 2015 00:00:00 +0530 Sun, 24 Jan 2016 18:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=271013 Section 14A read with Rule 8D could not sustain the major disallowance where the assessee had substantial own funds, the investment was carried forward from earlier years, and the Assessing Officer had applied Rule 8D without recording the required satisfaction; only a small management-expense element was retained. Interest on hire purchase loans classified as NPAs in the hands of an NBFC was not taxable on accrual basis because RBI prudential norms required income recognition only on receipt basis, and mere book entries or borrower confirmations did not create real income. A difference in opening hire purchase loan balance could not be taxed in the year under appeal unless the Revenue showed that the alleged unexplained amount arose in that year. Case-Laws Income Tax Fri, 04 Dec 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=271013