https://www.taxtmi.com/caselaws?id=777095 Where interest-free own funds and other non-interest-bearing funds exceed investments in tax-free securities, the investment is presumed to have been made from such funds and a section 14A read with Rule 8D(2)(ii) disallowance is not warranted. A later borrowing cannot be linked to an earlier investment on these facts. On section 40(a)(ia), short deduction of tax because the payer followed a different TDS provision does not by itself justify disallowance, and the curative proviso applies retrospectively where the payees have paid tax and the payer is not treated as in default. The Revenue's challenge therefore failed and the disallowances remained deleted. en-us Thu, 14 Aug 2025 00:00:00 +0530 Tue, 28 Apr 2026 17:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777095 Where interest-free own funds and other non-interest-bearing funds exceed investments in tax-free securities, the investment is presumed to have been made from such funds and a section 14A read with Rule 8D(2)(ii) disallowance is not warranted. A later borrowing cannot be linked to an earlier investment on these facts. On section 40(a)(ia), short deduction of tax because the payer followed a different TDS provision does not by itself justify disallowance, and the curative proviso applies retrospectively where the payees have paid tax and the payer is not treated as in default. The Revenue's challenge therefore failed and the disallowances remained deleted. Case-Laws Income Tax Thu, 14 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777095