https://www.taxtmi.com/caselaws?id=780202 ITAT (Ahmedabad) upheld CIT(A)'s restriction of the Rule 8D disallowance to Rs.10,00,000, finding the AO failed to record the required satisfaction and mechanically applied Rule 8D(2). The Tribunal also confirmed deletion of the AO's addition for write-off of loans to a 100% foreign subsidiary, holding the advances were incurred in the course of and incidental to the assessee's business and the write-off constituted an allowable business loss; decision was against revenue. Deletion of the book-profit adjustment under section 115JB by CIT(A) was also sustained. en-us Thu, 09 Oct 2025 00:00:00 +0530 Fri, 24 Oct 2025 11:00:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780202 ITAT (Ahmedabad) upheld CIT(A)'s restriction of the Rule 8D disallowance to Rs.10,00,000, finding the AO failed to record the required satisfaction and mechanically applied Rule 8D(2). The Tribunal also confirmed deletion of the AO's addition for write-off of loans to a 100% foreign subsidiary, holding the advances were incurred in the course of and incidental to the assessee's business and the write-off constituted an allowable business loss; decision was against revenue. Deletion of the book-profit adjustment under section 115JB by CIT(A) was also sustained. Case-Laws Income Tax Thu, 09 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780202