https://www.taxtmi.com/caselaws?id=758231 ITAT Delhi held that where assessee made suo moto disallowance under section 14A, AO must record objective satisfaction with cogent reasons why such disallowance is incorrect before applying Rule 8D(2) computation mechanism. Since AO failed to do so, only assessee's suo moto disallowance was sustained. Tribunal also directed that Rule 8D(2) mechanism cannot be applied for book profit computation under section 115JB, following Special Bench precedent in Vireet Investments case. Additionally, painting expenditure was allowed as revenue expenditure based on assessee's own case precedent. en-us Thu, 29 Aug 2024 00:00:00 +0530 Mon, 09 Sep 2024 16:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758231 ITAT Delhi held that where assessee made suo moto disallowance under section 14A, AO must record objective satisfaction with cogent reasons why such disallowance is incorrect before applying Rule 8D(2) computation mechanism. Since AO failed to do so, only assessee's suo moto disallowance was sustained. Tribunal also directed that Rule 8D(2) mechanism cannot be applied for book profit computation under section 115JB, following Special Bench precedent in Vireet Investments case. Additionally, painting expenditure was allowed as revenue expenditure based on assessee's own case precedent. Case-Laws Income Tax Thu, 29 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758231