https://www.taxtmi.com/caselaws?id=352139 Disallowance under section 14A read with Rule 8D was held unsustainable because the assessee had substantial own funds, including share capital and reserves, far exceeding the investments yielding exempt dividend income, and no fresh investment was made during the year. The Assessing Officer also failed to record the requisite dissatisfaction with the assessee's claim on the basis of its accounts before applying Rule 8D, so the presumption arose that the investments came from interest-free funds. The ad hoc restriction made by the first appellate authority lacked proper foundation. The Revenue's appeal was rejected, the cross-objections succeeded, and the addition was deleted. en-us Thu, 07 Dec 2017 00:00:00 +0530 Fri, 08 Dec 2017 09:20:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=352139 Disallowance under section 14A read with Rule 8D was held unsustainable because the assessee had substantial own funds, including share capital and reserves, far exceeding the investments yielding exempt dividend income, and no fresh investment was made during the year. The Assessing Officer also failed to record the requisite dissatisfaction with the assessee's claim on the basis of its accounts before applying Rule 8D, so the presumption arose that the investments came from interest-free funds. The ad hoc restriction made by the first appellate authority lacked proper foundation. The Revenue's appeal was rejected, the cross-objections succeeded, and the addition was deleted. Case-Laws Income Tax Thu, 07 Dec 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=352139