https://www.taxtmi.com/caselaws?id=462256 ITAT Chandigarh dismissed revenue's appeal regarding disallowance under Section 14A read with Rule 8D. The assessee had voluntarily disallowed 49% of expenses on scientific basis, but AO mechanically applied Rule 8D without establishing dissatisfaction with assessee's claim. The tribunal held that Rule 8D application is not automatic and requires AO's dissatisfaction with correctness of assessee's disallowance. Since AO's disallowance of Rs. 61,90,287 exceeded total expenditure of Rs. 56,91,320, it was unreasonable. CIT(A)'s deletion of disallowance was upheld. en-us Tue, 24 Apr 2018 00:00:00 +0530 Thu, 05 Jun 2025 15:03:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462256 ITAT Chandigarh dismissed revenue's appeal regarding disallowance under Section 14A read with Rule 8D. The assessee had voluntarily disallowed 49% of expenses on scientific basis, but AO mechanically applied Rule 8D without establishing dissatisfaction with assessee's claim. The tribunal held that Rule 8D application is not automatic and requires AO's dissatisfaction with correctness of assessee's disallowance. Since AO's disallowance of Rs. 61,90,287 exceeded total expenditure of Rs. 56,91,320, it was unreasonable. CIT(A)'s deletion of disallowance was upheld. Case-Laws Income Tax Tue, 24 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462256