https://www.taxtmi.com/caselaws?id=399128 HC allowed the appeal for the assessee, holding that disallowance under s.14A read with Rule 8D cannot exceed the exempted income (dividends) of the assessment year. The Assessing Authority must record satisfaction and give cogent reasons rejecting the assessee's apportionment (or claim of no expenditure) and afford hearing before invoking the computation method under Rule 8D. A negative disallowance cannot be treated as hypothetical taxable income. The assessment disallowance was set aside as excessive and procedurally unsound. en-us Wed, 30 Sep 2020 00:00:00 +0530 Fri, 05 Sep 2025 12:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=399128 HC allowed the appeal for the assessee, holding that disallowance under s.14A read with Rule 8D cannot exceed the exempted income (dividends) of the assessment year. The Assessing Authority must record satisfaction and give cogent reasons rejecting the assessee's apportionment (or claim of no expenditure) and afford hearing before invoking the computation method under Rule 8D. A negative disallowance cannot be treated as hypothetical taxable income. The assessment disallowance was set aside as excessive and procedurally unsound. Case-Laws Income Tax Wed, 30 Sep 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=399128