https://www.taxtmi.com/caselaws?id=763070 Disallowance under s.14A r/w Rule 8D was in issue, specifically whether the AO could invoke Rule 8D without first recording dissatisfaction with the assessee's own computation of expenditure attributable to exempt income. The HC held that Rule 8D can be applied only where the AO finds the assessee's allocation to be erroneous or inadequate; since neither the AO nor CIT(A)/ITAT identified any defect or inadequacy in the assessee's computation, resort to Rule 8D was impermissible. The disallowance was deleted and the appeal was decided in favour of the assessee. en-us Tue, 03 Dec 2024 00:00:00 +0530 Tue, 23 Dec 2025 12:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763070 Disallowance under s.14A r/w Rule 8D was in issue, specifically whether the AO could invoke Rule 8D without first recording dissatisfaction with the assessee's own computation of expenditure attributable to exempt income. The HC held that Rule 8D can be applied only where the AO finds the assessee's allocation to be erroneous or inadequate; since neither the AO nor CIT(A)/ITAT identified any defect or inadequacy in the assessee's computation, resort to Rule 8D was impermissible. The disallowance was deleted and the appeal was decided in favour of the assessee. Case-Laws Income Tax Tue, 03 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763070