https://www.taxtmi.com/caselaws?id=775867 The ITAT DELHI-AT remanded the issue of disallowance under section 14A read with Rule 8D to the AO for fresh examination. The AO is directed to consider only income-yielding investments for disallowance under Rule 8D(2)(iii) and to verify whether sufficient interest-free funds were available for such investments to determine disallowance under Rule 8D(2)(ii). The AO must provide the assessee an opportunity to be heard before deciding. The tribunal rejected the assessee's contention that no satisfaction was recorded by the AO for making disallowance under section 14A, holding that the AO had duly recorded dissatisfaction with the assessee's explanations after examining financials and replies. Consequently, the disallowance under section 14A was upheld subject to the AO's fresh consideration in accordance with the directions. en-us Wed, 30 Jul 2025 00:00:00 +0530 Fri, 01 Aug 2025 08:15:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775867 The ITAT DELHI-AT remanded the issue of disallowance under section 14A read with Rule 8D to the AO for fresh examination. The AO is directed to consider only income-yielding investments for disallowance under Rule 8D(2)(iii) and to verify whether sufficient interest-free funds were available for such investments to determine disallowance under Rule 8D(2)(ii). The AO must provide the assessee an opportunity to be heard before deciding. The tribunal rejected the assessee's contention that no satisfaction was recorded by the AO for making disallowance under section 14A, holding that the AO had duly recorded dissatisfaction with the assessee's explanations after examining financials and replies. Consequently, the disallowance under section 14A was upheld subject to the AO's fresh consideration in accordance with the directions. Case-Laws Income Tax Wed, 30 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775867