https://www.taxtmi.com/caselaws?id=461830 ITAT Mumbai held that AO cannot invoke section 14A r.w.r. 8D without recording satisfaction as mandated under section 14A(2). The tribunal accepted assessee's suo-moto disallowance based on scientific computation method, following precedent from assessee's own case for AY 2007-08 to 2013-14 and Bombay HC decision in Asian Paints Ltd. For section 115JB computation, disallowance was restricted to actual expenditure incurred rather than rule 8D computation, following Vireet Investment precedent. Interest under section 234C was directed to be computed on returned income instead of assessed income. All grounds raised by assessee were allowed. en-us Tue, 31 Dec 2024 00:00:00 +0530 Fri, 02 May 2025 11:18:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461830 ITAT Mumbai held that AO cannot invoke section 14A r.w.r. 8D without recording satisfaction as mandated under section 14A(2). The tribunal accepted assessee's suo-moto disallowance based on scientific computation method, following precedent from assessee's own case for AY 2007-08 to 2013-14 and Bombay HC decision in Asian Paints Ltd. For section 115JB computation, disallowance was restricted to actual expenditure incurred rather than rule 8D computation, following Vireet Investment precedent. Interest under section 234C was directed to be computed on returned income instead of assessed income. All grounds raised by assessee were allowed. Case-Laws Income Tax Tue, 31 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461830