https://www.taxtmi.com/caselaws?id=462448 The Tribunal allowed the assessee's appeal and deleted the disallowance under section 14A read with Rule 8D(2) of the Income Tax Rules. The AO had ignored the assessee's suo moto disallowance of Rs. 1.22 crores and applied Rule 8D(2) formula, resulting in a disallowance of Rs. 6.05 crores. The Tribunal found the AO's approach flawed as the foundational premise that the assessee incurred substantial interest expenditure for earning exempt income was factually incorrect, with actual interest expenditure being only Rs. 18,436. The AO failed to record objective satisfaction before rejecting the assessee's disallowance as mandated under section 14A(2) read with Rule 8D(1). The disallowance was deleted both under normal provisions and for book profit computation under section 115JB. en-us Wed, 22 May 2024 00:00:00 +0530 Mon, 23 Jun 2025 19:25:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462448 The Tribunal allowed the assessee's appeal and deleted the disallowance under section 14A read with Rule 8D(2) of the Income Tax Rules. The AO had ignored the assessee's suo moto disallowance of Rs. 1.22 crores and applied Rule 8D(2) formula, resulting in a disallowance of Rs. 6.05 crores. The Tribunal found the AO's approach flawed as the foundational premise that the assessee incurred substantial interest expenditure for earning exempt income was factually incorrect, with actual interest expenditure being only Rs. 18,436. The AO failed to record objective satisfaction before rejecting the assessee's disallowance as mandated under section 14A(2) read with Rule 8D(1). The disallowance was deleted both under normal provisions and for book profit computation under section 115JB. Case-Laws Income Tax Wed, 22 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462448