https://www.taxtmi.com/caselaws?id=445090 Rule 8D may be invoked only after the Assessing Officer objectively records dissatisfaction with the taxpayer's expenditure computation upon examining the accounts; general observations are insufficient. A disallowance relating to exempt income cannot be mechanically carried into book-profit computation, which must be based on the profit and loss account and permitted statutory adjustments. Uncertified scientific research expenditure requires factual verification where reasons for non-certification are unavailable. Interest on an income-tax refund not routed through audited accounts under a consistent accounting policy is not includible in book profit. Claims concerning compulsory-acquisition capital gains, foreign tax credit and certain transfer-pricing comparables require fresh verification, while genuine preference-share application money cannot be re-characterised as a loan solely because part was refunded before allotment. en-us Wed, 18 Oct 2023 00:00:00 +0530 Wed, 31 Jan 2024 14:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445090 Rule 8D may be invoked only after the Assessing Officer objectively records dissatisfaction with the taxpayer's expenditure computation upon examining the accounts; general observations are insufficient. A disallowance relating to exempt income cannot be mechanically carried into book-profit computation, which must be based on the profit and loss account and permitted statutory adjustments. Uncertified scientific research expenditure requires factual verification where reasons for non-certification are unavailable. Interest on an income-tax refund not routed through audited accounts under a consistent accounting policy is not includible in book profit. Claims concerning compulsory-acquisition capital gains, foreign tax credit and certain transfer-pricing comparables require fresh verification, while genuine preference-share application money cannot be re-characterised as a loan solely because part was refunded before allotment. Case-Laws Income Tax Wed, 18 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445090