https://www.taxtmi.com/caselaws?id=462257 The ITAT Chandigarh allowed the assessee's appeal regarding disallowance under section 14A read with Rule 8D. The tribunal held that amended Rule 8D was prospective from 02.06.2016 and not applicable to assessment year 2012-13, following SC precedent in Essar Teleholding Ltd. The assessee had made suo moto disallowance proportionate to dividend income without fresh investments during the year. The AO failed to provide cogent reasons for rejecting the suo moto disallowance and mechanically applied Rule 8D provisions without proper satisfaction recording. The CIT(A) erred in upholding the additional disallowance without considering these aspects. en-us Mon, 22 Aug 2022 00:00:00 +0530 Thu, 05 Jun 2025 19:01:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462257 The ITAT Chandigarh allowed the assessee's appeal regarding disallowance under section 14A read with Rule 8D. The tribunal held that amended Rule 8D was prospective from 02.06.2016 and not applicable to assessment year 2012-13, following SC precedent in Essar Teleholding Ltd. The assessee had made suo moto disallowance proportionate to dividend income without fresh investments during the year. The AO failed to provide cogent reasons for rejecting the suo moto disallowance and mechanically applied Rule 8D provisions without proper satisfaction recording. The CIT(A) erred in upholding the additional disallowance without considering these aspects. Case-Laws Income Tax Mon, 22 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462257