https://www.taxtmi.com/caselaws?id=774827 ITAT Hyderabad allowed the assessee's appeal against PCIT's revision order u/s 263 regarding disallowance u/s 14A read with Rule 8D. For AY 2020-21, the tribunal held that AO had conducted proper enquiry and taken a plausible view after considering assessee's submissions, hence PCIT cannot substitute his judgment unless AO's view is legally unsustainable. For AY 2021-22, since dividend income and capital gains became taxable and assessee offered them for taxation without claiming exemptions u/s 10(34) and 10(38), no disallowance u/s 14A arises. PCIT incorrectly applied CBDT Circular 5/2014 despite law changes from AY 2021-22 onwards. en-us Fri, 11 Jul 2025 00:00:00 +0530 Tue, 15 Jul 2025 08:39:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774827 ITAT Hyderabad allowed the assessee's appeal against PCIT's revision order u/s 263 regarding disallowance u/s 14A read with Rule 8D. For AY 2020-21, the tribunal held that AO had conducted proper enquiry and taken a plausible view after considering assessee's submissions, hence PCIT cannot substitute his judgment unless AO's view is legally unsustainable. For AY 2021-22, since dividend income and capital gains became taxable and assessee offered them for taxation without claiming exemptions u/s 10(34) and 10(38), no disallowance u/s 14A arises. PCIT incorrectly applied CBDT Circular 5/2014 despite law changes from AY 2021-22 onwards. Case-Laws Income Tax Fri, 11 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774827