https://www.taxtmi.com/caselaws?id=774537 The Gujarat HC held that the AO lacked jurisdiction to reopen assessment under Section 147 for disallowance under Section 14A. Following South Indian Bank Limited precedent, the AO cannot assume jurisdiction to reopen assessment for Section 14A disallowance based on balance sheet and profit-loss account scrutinized during regular assessment. Since the assessee used mixed funds for investment and business purposes without additional information available, and Section 14A was inapplicable, Rule 8D could not be applied. The assessee's appeal was allowed. en-us Mon, 16 Jun 2025 00:00:00 +0530 Fri, 27 Mar 2026 15:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774537 The Gujarat HC held that the AO lacked jurisdiction to reopen assessment under Section 147 for disallowance under Section 14A. Following South Indian Bank Limited precedent, the AO cannot assume jurisdiction to reopen assessment for Section 14A disallowance based on balance sheet and profit-loss account scrutinized during regular assessment. Since the assessee used mixed funds for investment and business purposes without additional information available, and Section 14A was inapplicable, Rule 8D could not be applied. The assessee's appeal was allowed. Case-Laws Income Tax Mon, 16 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774537