https://www.taxtmi.com/caselaws?id=464429 ITAT DELHI - AT allowed the appeal and deleted the suo moto disallowance under s.14A r.w. r.8D. The Tribunal held the AO failed to record the requisite satisfaction (per SC precedent) and did not examine the assessee's financials, P&L or nature of funds/loans before invoking apportionment; the exempt income arose from subsidiary investments and no basis existed to attribute direct or indirect expenses. Consequential additions were set aside. en-us Thu, 14 Sep 2023 00:00:00 +0530 Wed, 29 Oct 2025 12:02:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464429 ITAT DELHI - AT allowed the appeal and deleted the suo moto disallowance under s.14A r.w. r.8D. The Tribunal held the AO failed to record the requisite satisfaction (per SC precedent) and did not examine the assessee's financials, P&L or nature of funds/loans before invoking apportionment; the exempt income arose from subsidiary investments and no basis existed to attribute direct or indirect expenses. Consequential additions were set aside. Case-Laws Income Tax Thu, 14 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464429