https://www.taxtmi.com/caselaws?id=387856 Rule 8D can be invoked only after the Assessing Officer, having regard to the accounts, objectively records dissatisfaction with the assessee's claim or suo motu disallowance under section 14A(2). A bare conclusion that the assessee's method is inconsistent with Rule 8D is insufficient unless the assessment order first shows account-based dissatisfaction with the disallowance offered. On the facts, the recorded reasons did not meet that statutory threshold, and the Tribunal's view was a possible view. The challenge based on reliance on an earlier year's order did not change that result, so the disallowance under Rule 8D was not justified. en-us Tue, 15 Oct 2019 00:00:00 +0530 Wed, 28 Jan 2026 13:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=387856 Rule 8D can be invoked only after the Assessing Officer, having regard to the accounts, objectively records dissatisfaction with the assessee's claim or suo motu disallowance under section 14A(2). A bare conclusion that the assessee's method is inconsistent with Rule 8D is insufficient unless the assessment order first shows account-based dissatisfaction with the disallowance offered. On the facts, the recorded reasons did not meet that statutory threshold, and the Tribunal's view was a possible view. The challenge based on reliance on an earlier year's order did not change that result, so the disallowance under Rule 8D was not justified. Case-Laws Income Tax Tue, 15 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=387856