https://www.taxtmi.com/caselaws?id=463310 HC held that ITAT's acceptance of additional grounds of appeal under the Pruthvi Brokers principle does not raise a substantial question of law. ITAT's referral permitting allowance of bad debts allocable to urban branches likewise is not a substantial question; the AO must apportion urban and rural amounts when giving effect. ITAT's refusal to uphold a disallowance under section 14A read with Rule 8D(2)(i) without verifying surplus funds is also not substantial. However, HC admitted the appeal on a substantial question whether strategic investments can be excluded from disallowance under section 14A read with Rule 8D(2)(iii). en-us Wed, 24 Apr 2024 00:00:00 +0530 Fri, 22 Aug 2025 20:06:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463310 HC held that ITAT's acceptance of additional grounds of appeal under the Pruthvi Brokers principle does not raise a substantial question of law. ITAT's referral permitting allowance of bad debts allocable to urban branches likewise is not a substantial question; the AO must apportion urban and rural amounts when giving effect. ITAT's refusal to uphold a disallowance under section 14A read with Rule 8D(2)(i) without verifying surplus funds is also not substantial. However, HC admitted the appeal on a substantial question whether strategic investments can be excluded from disallowance under section 14A read with Rule 8D(2)(iii). Case-Laws Income Tax Wed, 24 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463310