https://www.taxtmi.com/caselaws?id=329252 Whether disallowance under s.14A was warranted despite the assessee's suo motu disallowance in the return turned on availability of interest-free funds and permissibility of a claim inconsistent with the return. The ITAT held, on materials on record, that the assessee's interest-free funds substantially exceeded its interest-free investments, negating any presumption of interest expenditure attributable to exempt income; it followed binding HC rulings in the assessee's own later years, noting the SLP against them was dismissed. It further applied SC authority permitting a legal claim to ensure taxation of real income notwithstanding return disclosures. The disallowance was deleted and the appeal was dismissed against the revenue. en-us Mon, 13 Jun 2016 00:00:00 +0530 Fri, 02 Jan 2026 12:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=329252 Whether disallowance under s.14A was warranted despite the assessee's suo motu disallowance in the return turned on availability of interest-free funds and permissibility of a claim inconsistent with the return. The ITAT held, on materials on record, that the assessee's interest-free funds substantially exceeded its interest-free investments, negating any presumption of interest expenditure attributable to exempt income; it followed binding HC rulings in the assessee's own later years, noting the SLP against them was dismissed. It further applied SC authority permitting a legal claim to ensure taxation of real income notwithstanding return disclosures. The disallowance was deleted and the appeal was dismissed against the revenue. Case-Laws Income Tax Mon, 13 Jun 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=329252