https://www.taxtmi.com/caselaws?id=335351 The HC upheld the disallowance made under Section 14A read with Rule 8D. It held that once the AO finds the assessee's self-computed disallowance prima facie inconsistent with a fair application of Section 14A, the AO is mandated to apply the prescribed methodology in Rule 8D(2). The Court ruled that an elaborate analytical exercise by the AO, reflecting application of mind to the statutory parameters, constitutes sufficient compliance with the requirement to record dissatisfaction, even if not expressed in specific terms. The disallowance computed under Rule 8D was thus sustained. en-us Mon, 21 Nov 2016 00:00:00 +0530 Wed, 17 Dec 2025 11:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=335351 The HC upheld the disallowance made under Section 14A read with Rule 8D. It held that once the AO finds the assessee's self-computed disallowance prima facie inconsistent with a fair application of Section 14A, the AO is mandated to apply the prescribed methodology in Rule 8D(2). The Court ruled that an elaborate analytical exercise by the AO, reflecting application of mind to the statutory parameters, constitutes sufficient compliance with the requirement to record dissatisfaction, even if not expressed in specific terms. The disallowance computed under Rule 8D was thus sustained. Case-Laws Income Tax Mon, 21 Nov 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=335351