https://www.taxtmi.com/caselaws?id=425242 Disallowance under section 14A read with Rule 8D was held unsustainable where the Tribunal, on materially similar facts, followed an earlier decision in the assessee's own case and declined mechanical application of Rule 8D. The Court noted that the Assessing Officer had recorded satisfaction and made his own assessment, but rejected the challenge based on a supposed factual distinction. The controlling principle stated was that Rule 8D cannot be applied mechanically without a sustainable basis for disallowance, and the Tribunal was correct in relying on the earlier precedent. The issue was answered in favour of the assessee. en-us Tue, 14 Jun 2022 00:00:00 +0530 Mon, 18 Jul 2022 22:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=425242 Disallowance under section 14A read with Rule 8D was held unsustainable where the Tribunal, on materially similar facts, followed an earlier decision in the assessee's own case and declined mechanical application of Rule 8D. The Court noted that the Assessing Officer had recorded satisfaction and made his own assessment, but rejected the challenge based on a supposed factual distinction. The controlling principle stated was that Rule 8D cannot be applied mechanically without a sustainable basis for disallowance, and the Tribunal was correct in relying on the earlier precedent. The issue was answered in favour of the assessee. Case-Laws Income Tax Tue, 14 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=425242