https://www.taxtmi.com/caselaws?id=290565 Section 14A disallowance can be made only after the Assessing Officer examines the accounts and records objective dissatisfaction with the assessee's claim that no expenditure is relatable to exempt income. Rule 8D is only a computation mechanism and cannot be applied mechanically without that statutory precondition. Where the investments were stated to be in subsidiary companies for business purposes and no interest cost was shown for earning exempt income, a disallowance made without recorded reasons was unsustainable. The section 14A read with Rule 8D disallowance was therefore not justified and was deleted. en-us Thu, 31 Aug 2017 00:00:00 +0530 Tue, 06 Oct 2020 10:46:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=290565 Section 14A disallowance can be made only after the Assessing Officer examines the accounts and records objective dissatisfaction with the assessee's claim that no expenditure is relatable to exempt income. Rule 8D is only a computation mechanism and cannot be applied mechanically without that statutory precondition. Where the investments were stated to be in subsidiary companies for business purposes and no interest cost was shown for earning exempt income, a disallowance made without recorded reasons was unsustainable. The section 14A read with Rule 8D disallowance was therefore not justified and was deleted. Case-Laws Income Tax Thu, 31 Aug 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=290565