https://www.taxtmi.com/caselaws?id=754453 The ITAT Delhi ruled in favor of the assessee on multiple grounds. The tribunal deleted disallowances under Section 14A, finding that the AO failed to record mandatory satisfaction before applying Rule 8D, and that investments were made from own funds, not borrowed funds. The tribunal also held that no Section 14A disallowance should be made while computing book profit under Section 115JB, following the Sobha Developers precedent. Additionally, self-Cenvat credit cannot be included in book profit calculations. The CIT(A)'s decisions allowing deductions under Sections 80IB and 80IC, and deleting additions for unexplained cash, were upheld. en-us Thu, 20 Jun 2024 00:00:00 +0530 Mon, 24 Jun 2024 16:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754453 The ITAT Delhi ruled in favor of the assessee on multiple grounds. The tribunal deleted disallowances under Section 14A, finding that the AO failed to record mandatory satisfaction before applying Rule 8D, and that investments were made from own funds, not borrowed funds. The tribunal also held that no Section 14A disallowance should be made while computing book profit under Section 115JB, following the Sobha Developers precedent. Additionally, self-Cenvat credit cannot be included in book profit calculations. The CIT(A)'s decisions allowing deductions under Sections 80IB and 80IC, and deleting additions for unexplained cash, were upheld. Case-Laws Income Tax Thu, 20 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754453